The assessee, a French company, received technology and strategic information system service fees from its Indian group companies. The services were rendered by the assessee’s own personnel outside India and the Indian entities were merely recipients of standard services without being granted any licence or right to use any software or intellectual property. The Tribunal held that the receipts did not constitute royalty either under the Act or Article 12 of the India-France DTAA and were, therefore, not chargeable to tax in India. The assessee received management service fees for providing recurring general management services to its Indian group companies. No intellectual property, confidential information or technical know-how was made available to the recipients. The Tribunal held that the payments were neither royalty nor fees for technical services under the Act or the India-France DTAA and accordingly deleted the addition (AY. 2019-20).