IT/ILT : Payment received by applicant a US based technology company from its India based group company under non-exclusive Reseller Agreement for sale of applicant's content delivery solutions directly to customers in India, not taxable as FTS/FIS or Royalty under Act or India-US DTAA. Solutions provided by applicant are in nature of a 'standard facility' and do not cater to individual requirements of customer, moreover absent human intervention it cannot be termed as FTS under Explanation 2 to
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