The assessee, a tax resident of Malaysia, received payments from HCL Technologies Ltd. pursuant to a Master Service Agreement under which the parent and its foreign subsidiaries jointly rendered services to overseas customers and shared revenue in proportion to the services performed. The Assessing Officer treated the receipts as fees for technical services taxable in India and reopened the assessments. Following its decision in the assessee’s own case for earlier years, the Tribunal held that the arrangement was merely a revenue-sharing mechanism and not one involving the provision of technical services by the assessee to the Indian parent. Accordingly, the receipts were not taxable as fees for technical services under section 9(1)(vii), and the additions were deleted. (AY. 2012-13, 2013-14 to 2017-18)