Held that assessee, a resident of Finland, earned income from providing centralised group services such as communication, marketing, strategy, HR, treasury, finance and tax to its Indian subsidiaries; such income was taxable in India as a fee for technical services under Article 12 of the India–Finland DTAA. Tribunal also held that the guarantee fee from its Indian subsidiaries for providing corporate and performance guarantees, since providing guarantees was not a regular business activity but an obligation arising from the parent–subsidiary relationship, such fee was taxable in India as other income. (AY. 2022-23)