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of HC determined that subscription fees for standardized e-magazines do not constitute fees for technical services (FTS) under Section 9(1)(vii). The court held that mere access to technical database or literature does not qualify as technical services, which require specialized human intervention. The subscription content was generic and not specifically generated for any particular entity, thus falling outside the FTS definition. The assessment order was consequently set aside, with no substantial legal question warranting further examination of double taxation avoidance agreement (DTAA) provisions.
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