AO's FTS Classification Error: Employee Training Not Technical Services Under Article 12(4) of India-Portugal DTAA.

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....Fees for technical services’ (‘FTS’) - The conclusion drawn by the AO is not proper because the training simply advances the skill of the recipient-employees but falls short of providing any technical knowledge, experience, skill that enables the employees “to apply the technology contained therein”. - decision of the AO in treating the amount as FTS, is not correct because such consideration does not fall within the purview of FTS under Article 12(4) of the DTAA read with Article 12(4) of the DTAA between India- Portuguese - AT....