Held, that the assessee’s provision of legal services under Indian engagements did not fall within the meaning of “fees for technical services” (as defined in article 13 of the Double Taxation Avoidance Agreement) since the services did not make available any technical knowledge, experience, skills, know-how or process. Therefore, the income received therefrom, being in the nature of business income, was not taxable in India in the absence of a permanent establishment of the assessee in India in terms of articles 5 and 7 of the Double Taxation Avoidance Agreement between India and the United Kingdom. (AY. 2012-13, 2013-14)