Assessee, a French company, provided information technology support services and management services to its group entity in India.  Assessing Officer held that payment received by assessee from its AE was in terms of service agreement covered by definition of royalty as well as FTS under article 13(3) of India-France DTAA and amount was taxable as royalty under Explanation 2 to section 9(1)(vi). Tribunal  held such income was neither royalty nor FTS and, therefore, not taxable either within Act or within DTAA. Addition is deleted. (AY. 2020-21)