Assessee, a Netherlands based company, was engaged in business of executive search service as well as providing technology, software and related support services to its group companies. It had entered into a licence agreement (LA) with its Indian company (SS) whereby it granted license to SS to use trade-name, trademark, and rights to use software owned by it against license fee which was offered to tax as royalty. It had also entered into a service agreement (SA) whereby, SS and assessee agreed to provide, on a principal-to-principal basis, support and services to each other in relation to executive search assignments against executive search service fee (ESF).  Assessee claimed that search fee was in nature of business income and was not taxable in India in absence of a PE in India. Tribunal held that  search fee and license fee were distinct from each other and search fee received under SA was independent of LA and was not taxable in India as FTS or royalty under article 12(5)(a). Followed order of earlier year.   Reimbursement of expenses  is not taxable as FTS. Management service fee matter remanded for de novo consideration.   (AY. 2019-20 )