Assessee, an Indian company, made payments to its US parent company (AE) towards administrative services, IT services, technical services and royalty without deduction of tax at source. Assessing Officer held that since foreign party performed all administrative services as part of group global policies to maintain control over employed staff in India, services were in nature of managerial service. CIT(A) affirmed the order of the AO. Tribunal held that though Assessing Officer had observed that AE had made available technical knowledge to assessee, but had failed to bring on record any relevant material to support same and, consequently, payments made by assessee could not be treated to be in nature of FTS.(AY. 2013-14)