Held that for the purpose of uploading the banner advertisement the advertisement related information was put up at the interface provided by Ireland. While uploading the advertisement, the assessee-company did not have any control over the functioning of the interface provided by F, Ireland. The entire operation and maintenance of the server while providing the advertisement platform was under the control of F, Ireland. The assessee was taking the privilege of platform of F, Ireland which was not either in the nature of royalty or technical services. The payment terms defined in the payment agreement with F, Ireland clearly indicated that F, Ireland would provide platform banner for advertisement to the assessee-company. Thus, there was no element of fees for technical services or royalty involved. The Assessing Officer as well as the Commissioner (Appeals) had erred in holding that the services came under the purview of fees for technical services or royalty. (AY. 2014-15, 2015-16)