Assessee-company was engaged in business of manufacturing of master batches and engineering plastics compounds. It made payment to two foreign scientists for professional services rendered by them. The AO has held that the assessee  was liable to deduct tax at source. Tribunal held that services had been provided by individuals which were in nature of Independent scientific services covered under article 14; that according to article 12(5)(b) meaning of term fees for technical services specifically excludes income covered under articles 14 and 15; and that two scientists had no fixed PE in India and both had not stayed in India for 183 days or more. Accordingly  no tax was required to be deducted at source by assessee while making payment to two scientists. (AY. 2014-15)