Held that disaster recovery/back-up services, helpdesk support services, user administration, maintenance of IT infrastructure support services and telecom services provided by the assessee to its sister concern in order to achieve a standardized IT environment do not make available any technical knowledge, experience, skills, etc., to the recipient, since the latter cannot at any time independently manage the IT environment and therefore, the amount received by the assessee on account of said services does not fall within the ambit of ‘fee for included services’ as defined under art. 12 of India-US DTAA and hence, not taxable in India. (AY. 2014-15 to 2017-18)