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Recently, the Authority for Advance Rulings in the case of Oxford University Press (the applicant) held that services rendered by a non-resident (the Executive), for promotion of sales and brand name of the applicant in Sri Lanka, are not managerial, technical or consultancy services under the provisions of the Income-tax Act, 1961 (the Act). During the relevant year, the India – Sri Lanka tax treaty (the tax treaty) did not contain Article on ‘Fees for Technical Services’. Though the payment is covered under Article 14 dealing with Independent Personal Services of the tax treaty however, the same is not taxable in India. Accordingly, the payment made to the Executive is not taxable either under the Act or under the tax treaty.