The Assessing Officer held that the consideration received by the assessee as fees for technical services under section 9(1)(vii) of the Income-tax Act, 1961 and article 12 of the Double Taxation Avoidance Agreement between India and Singapore. The Dispute Resolution Panel affirmed this. On appeal the Tribunal held that the receipt cannot be taxes as fees for technical services. (AY.2018-19, 2019-20)