Services received by ONGC from Dutch Co. not FTS in absence of transmitting of any technical knowledge

IT/ILT : Where ONGC had benefit of services provided by assessee, a Dutch company, but did not gain any technical knowledge, experience or skill which would enable ONGC to undertake such an endeavour independently in future without aid and assistance of assessee, payment made to assessee for such services would not fall within scope of article 12 of DTAA between India and Netherlands and would not be taxable in India

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