Appellant had an infrastructure data centre at Singapore  Under Infrastructure Data Centre (IDC) agreement, assessee Singapore company provided IT infrastructure management and mail box/website hosting services to its India group companies from Singapore . Websites/applications/softwares hosted by Indian group companies on data centre in Singapore were web ordering application, corporate website, websites created for customers of Edenred India entities while making a loyalty program for them . Indian group companies neither accessed nor used CPU of appellant . All that Indian group companies received were standard IDC services . Bandwith and networking infrastructure was used by appellant to render IDC services .Tribunal held that  Indian companies only got output of usages of such bandwith and network . Appellant only provided service by using its hardware/security devices/personnel and there was no use of any Software; no embedded/secret software was developed by appellant – Further, consideration was for IDC services and not any specific program – Whether revenue under IDC agreement ought not to be taxed in hands of appellant as royalty under Act and/or India-Singapore DTAA Assessee received management fee from Indian company SurfGold for consultancy services to support sales activities of SurfGold, legal services, financial advisory services and human resource assistance – Such management services were provided only to support SurfGold in carrying on its business efficiently and in line with business model, policies and best practices followed by assessee’s group . Tribunal held that  these services did not make available any technical knowledge, skill, know-how or processes to SurfGold  Accordingly   Assessing Officer  as well as DRP was not justified in holding management services to be fees for technical services .  Referral services/other services were provided by assessee Singapore company to support Indian company Surf Gold in carrying on business . These services did not make available any technical knowledge, skill, know-how or processes to SurfGold because there was no transmission of technical knowledge, experience, skill etc. from assessee to SurfGold or its clients . Tribunal held that  revenue received under referral agreement was not taxable in hands of assessee as royalty under Act and/or India-Singapore DTAA or FTS under India-Singapore DTAA .  (AY. 2010 -11, to 2012 -13 )