Intermediary services by appellant not taxable in India; don't transfer technical skills to BTIN, not FTS under law.

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....Taxation of intermediary services - Intermediary services rendered by the appellant do not make available any technical knowledge, skill etc to BTIN and BTIN is not a equipped to apply technology contained in services rendered by the appellant. Therefore, the intermediary services provided by the appellant to BTIN do not tantamount to FTS and accordingly, shall not be taxable in India. - AT....