Assessee, a Singapore based company, engaged in business of manufacturing and sale of glass fibers in India.  It had provided bushing and fabrication services to Indian AE. The AO treated the said receipts as fees for technical services. DRP sustained the addition. On appeal the Tribunal held that   fabrication charges received by assessee from its Indian AE for manufacturing glass is  not FTS under India-Singapore DTAA. (AY. 2021-22)