Tribunal held that the non-resident company did not have any permanent establishment or any business connection in India and hence its income could be deemed to have accrued or arisen in India only if the payments were of the nature provided under section 9 of the Act.  The Tribunal also held that  section 9(1)(vii) provides for accrual of income only for the “fees for technical services” which includes specialised services like managerial, technical and consultancy. But the non-resident had not rendered any technical or managerial services to the assessee but was merely a project work procurement agent. The payments were only towards charges for procurement or orders and reimbursement of expenses and were not in the nature of “fees for technical services” and thus did not fall in the ambit of section 9 of the Act.  Accordingly the payments for procurement of orders were not subject to deduction of tax at source under section 195 of the Act and the demand for default and interest levied under section 201(1A) of the Act were liable to be deleted. Relied on   DR. Reddy laboratories ltd., IN RE (2016) 387 ITR 337 (AAR). (AY. 2015-16, 2016-17)