On appeal the Tribunal held that  the payment received  pertained to document handling and printing charges; assistance and support in estimating, review of kitchen design; legal services; telecommunications services, etc. which could neither be said to be made available to recipient nor could consist of development and transfer of any technical plan or a technical design. Services would not fall within ambit of FIS as per DTAA and amount received by assessee was not taxable under article 12(4). Tribunal also held that payments towards reimbursement of market data charges received by assessee-US based company from its Indian AEs was not royalty as per article 12 of India-US DTAA. (AY. 2013-14 to 2017-18)