Business Support Services / financial services not in the nature of technical services within the meaning of Article 12.5(b) of the DTA between India and the Netherlands

In Re Shell Technology India Private Limited (AAR) – The applicant is said to be providing scientific and technical services to Overseas Shell group entities. SSSABV, a company incorporated in Netherlands, through its branch in the Philippines, is currently providing back office financial services relating to accounts etc. to the applicant. It is seen that software are installed for that purpose; but it has not been clarified whether they are installed in India or in the Philippines. It appears to us that this aspect may not matter, as the software is used by the Philippines branch of S...