Held that the commission is not in the nature of fees for technical services as it did not constitute fees for managerial services. Managerial services entail an element of management of the business of the service recipient in a substantial manner. The mere provision of support services could not be labelled as managerial services. Hiring of outside parties to receive support in respect of the operational aspects of a business cannot qualify as managerial services unless the service provider lays down policies or executes such policies by managing the personnel of the service recipient. Commission earned by the assessee could thus not be charged to tax in India. That the subscription fees were not in the nature of royalty. Amounts received as consideration for the resale or use of computer software are not payments of royalty for the use of the copyright in the computer software. Accordingly, the sums received by the assessee did not give rise to any income taxable in India. (AY.2013-14)