Tribunal held that the leadership training provided by the assessee did not result in making available any technical knowledge, experience or skill, to the employees of the Indian company, which could enable them to use it later on. The Assessing Officer was not justified in considering the training fee as a consideration for rendering consultancy or technical services within the meaning of article 12(4)(b) of the Double Taxation Avoidance Agreement between India and Portugal. On the facts since the Assessing Officer had himself, in the assessment order, accepted that the assessee did not have any permanent establishment in India, the amount of training fees would also escape tax net as it could not be taxed as “business profits” under article 7 in the absence of there being any permanent establishment in India in terms of article 5. (AY. 2014-15)