Turnkey offshore management fees not FTS under Sec.9(1)(v) and DTAA, so taxation avoided; no PE or DAPE.

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....ITAT affirmed that fees received for turnkey offshore supply and management services do not constitute "Fees for Technical Services" under the Act or the India-UK DTAA because the services did not "make available" technical knowledge or skills to the recipient; the services were managerial, annually renewable, and passed arm's-length scrutiny, so taxation as FTS was unwarranted. Relying on similarity of legal and factual matrix with a prior assessment year, ITAT also held there was no permanent establishment or dependent agent PE (PE/DAPE) in India. Both grounds were decided in favor of the taxpayer, overturning the assessing authority's imposition of Indian taxing rights.....