Assessee, a Singapore based company, had entered into intra-group services agreement with Indian affiliates for providing management and support services which included marketing and sales services and operations and standardization services and received certain amount of consideration. Commissioner (Appeals) held  that amount received by assessee for providing such services was in nature of fee for technical services (FTS) under section 9(1)(vii) as well as article 12(4) of DTAA. Tribunal held that trainings did not ‘make available’ technical knowledge, experience, skill, know-how or processes and there was no transfer of technology, amount received by assessee was not taxable as FTS. (AY. 2010-11)