Assistance in financial and risk management decision is a ‘technical service’; FTS under India-US DT

IT/ILT : Where assessee-company was making use of advice, input experience, experimentation and assistance rendered by USA based company in its decision making process of financial and risk management, etc., services so rendered being technical in nature as mentioned in clause 4(b) of article 12 of India-US DTAA, assessee was liable to deduct tax at source while making payments for said services