Held that since services provided by assessee were not technical services which required technical knowledge, skill or experience and were general managerial services received from assessee on recurring basis, management fee received for said services would not be taxable as FIS under India US DTAA. As regards  Master consultant sharing agreement to supply manpower, since there was no rendition of technical or consultancy services which would enable Indian subsidiary to apply any technical knowledge, experience, skill, know-how on its own without recourse to manpower supplied by assessee, labour charges received by assessee would not be taxable as FIS under India-USA DTAA.  As reagrds miscellaneous services to third parties in India which consisted of access to published research reports by providing subscription for same, since assessee granted only a right to use copyrighted material rather than right to use copyright, subscription fees received by assessee would not be taxable as royalty under India-USA DTAA. (AY.  2010-11 to 2012-13)