Assessee, a US company, which is  engaged in business of providing global freight logistics services worldwide.  Assessing Officer made additions to income of assessee on account of sale of logistic services treating same as Fees for Technical Services (‘FTS’) under Act as well as India-USA DTAA. DRP up held the order of the Assessing Officer. On appeal  Tribunal following  assessee’s own case in earlier year held that amount received by assessee from freight/logistic support services could not be treated as FTS/FIS. Consequently, amount received by assessee in question could not be treated as FTS/FIS or royalty under Act as well as India-USA DTAA. Held that the amount received by assessee, a non-resident company, for reimbursement of global account management charges for services rendered outside India could not be treated as royalty under Act as well as India-USA DTAA. Held that the amount received by assessee, a non-resident company, for reimbursement of lease line charges for services rendered outside India could not be treated as royalty under Act as well as India-USA DTAA. (AY. 2021-22)