Administrative Services Not Classified as "Fees for Technical Services" u/s 9(1)(vii) or India-South Africa Tax Treaty.

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....Fees for technical services - the consideration received by the assessee for rendering purely administrative services, cannot be brought within the sweep of the definition of “FTS” within the meaning of Explanation 2 to Sec.9(1)(vii) of the Act or Article 12 of the India-South Africa tax treaty.....