Fee paid for global market survey to determine business prospects in India isn't 'FTS' under India-U

IT/ILT: Where assessee, an Indian company, had merely availed services of U.K. Company for global market survey to determine business prospects to carry out project in India, since these services were neither geared to nor did they 'make available' any technical knowledge, skill or experience to assessee or consisted of development and transfer of a technical man or technical design to assessee, article 13 of DTAA between India and U.K. could not apply