Assessee, a tax resident of Singapore, is  engaged in business of rendering management consultancy and other related services to hotels. It had entered into three separate agreements with third party Indian hotels and earned revenue towards management fee and license fee. The Assessing Officer held that  receipts are  for services ancillary and subsidiary to trade mark license agreement for use of trade mark and brand name, which was in nature of royalty and would fall within ambit of FTS under article 12(4)(a) of India-Singapore DTAA.  On appeal the Tribunal held that there is  nothing on record to demonstrate that while rendering services, assessee had made available technical knowledge, experience, skill, know-how or processing etc. to bring it within ambit of FTS under article 12(4)(b) of treaty. Held that reimbursement of cost received by assessee, could not be treated as FTS under article 12(4).(AY. 2018-19, 2019-20)