Held, that the services rendered under information technology and systems, applications and products support service agreement were completely different in nature and had no connection with the services rendered under the technical collaboration agreement. While the services rendered under the service agreement were for day-to-day office functioning and maintenance of the information technology infrastructure, the services rendered under the technical collaboration agreement were purely and strictly in connection with the drip irrigation system required for agricultural purposes. Therefore, the services rendered under the services agreement could not be considered ancillary and subsidiary to the services rendered under technical collaboration agreement. Further, they did not relate to application or enjoyment of right to property or information resulting in payment of royalty. Not taxable in India. (AY.2014-15, 2015-16)