Assessee, a UK based company, entered into intragroup agreement with its Indian AE and provided services pertaining to human resources, finance, legal and compliance and conducting of internal audit assurance work. Assessee received certain amount with respect to said services which was not offered to tax while filing return.Assessing Officer held that such receipts were for services in nature of FTS under article 13 and would be taxable in India. DRP affirmed the order of the Assessing Officer. On appeal the Tribunal held that from service agreement that services rendered by assessee were in nature of advisory services and assessee’s role was to assist AEs in making correct decision on aspects specifically referred to in agreement.Since such rendition of services did not result in transfer of technical knowledge, know-how, skill etc. to Indian AE, make available condition provided under article 13(4)(c) remained non-compliant and thus, receipts would not fall within definition of FTS as provided under article 13(4) of India-UK DTAA. (AY. 2018-19, 2019-20)