https://www.scconline.com/blog/post/2023/03/17/payment-received-by-assessee-from-foreign-company-for-business-support-is-not-fts-itat-legal-research-legal-news-updates/
Payment received by assessee from foreign company for business support services cannot be treated as FTS under Art. 12 (5) of India Netherlands DTAA: ITAT reiterates