The assessee claimed benefit of the provisions of article 13 of the Double Taxation Avoidance Agreement between India and the United Kingdom read with article 13 of the Double Taxation Avoidance Agreement between India and France and Protocol 7 to that Agreement according to which if the scope of taxability of fees for technical services is restricted on account of the Agreement between India and another Sate which is a member of the OECD then such limited scope would apply to the Double Taxation Avoidance Agreement between India and France in the same manner. The Assessing Officer held  that the nature of support services provided by the assessee to Indian entities were in the nature of fees for technical services and that the Protocol under the Double Taxation Avoidance Agreement between India and France could not be treated as forming part of the Double Taxation Avoidance Agreement itself unless there was a notification issued by the Government to incorporate the less restrictive provisions of the other treaty available. Accordingly he treated the revenue on account of intermediary services as taxable as fees for technical services. The Commissioner (Appeals) held that the amount received by the assessee during the year for provision of management support services was not taxable as fees for technical services under the Double Taxation Avoidance Agreement between India and France, since the make available test imported from the Double Taxation Avoidance Agreement between India and the United Kingdom into the Double Taxation Avoidance Agreement between India and France had not been satisfied in this case. On appeal  the Tribunal affirmed the order of the CIT(A). Notification No. S.O. 650(E) dt. 1-7-2000 (2000) 244 ITR 134 (St), Circular No. 3 of 2022, dt. 3-2-2022 (2022) 441 ITR 49 (St). (AY.2015-16)