Assessee, a non-resident company, had revived certain amount of consideration on account of subscription payments, training and professional fees. Assessing Officer held that said receipts were taxable as fee for technical services under article 12 of India-Netherlands DTAA.  DRP up held the order of the Assessing Officer. On appeal the Tribunal held that since assessee had merely granted only access to software and there was no transfer of technology by assessee, services rendered by assessee did not fall within definition of FTS. (AY. 2020-21, 2011-22)