The Tribunal allowing the appeal held that with respect to taxability of management support cost, the services provided by the assessee did not make available any technical knowledge, skill, know-how to the recipient. While the licence agreements for user of brand name were with various third party hotels in India, the agreement for provision of management support services was with the Indian subsidiary. Therefore, the amount received from provision of management support services was not ancillary and subsidiary to the licence agreement. Not taxable as fees for technical services .(AY. 2015-16 to 2016-17)