Section 90, 195 & 201 of the Income Tax Act, 1961 — DTAA — Training services provided by the U.S. company FIC to the assessee in connection with the software licensed by it to the latter did not make available any technology etc to the assessee and therefore the training fees paid by the assessee to FIC did not constitute fees for included services as defined in the Indo - USA DTAA ; Same could not be assessed as business profits as FIC has no PE in India — Reliance General Insurance Co Ltd vs. Income tax Officer [2018] 196 TTJ (Mumbai) 244