Payment for pre-clinical research was FTS as payer had right over patents and gained knowledge in re

IT/ILT: Where assessee had entered into agreement with a UK company and a Netherlands company for conducting pre-clinical research studies, since it had rights over patents, secret knowledge etc., attained during course of conducting research, services received by assessee fulfilled definition for 'technical services' as per provisions of section 9(1)(vii) and also definition for these technical services as per relevant DTAA with UK and Netherlands