Applicability of FCRA to Article Processing Fees (APC) Received from Foreign Author in Journal

I seek the views of professionals on the following issue under the Foreign Contribution (Regulation) Act,

2010.

A charitable trust in India publishes a research journal and collects article processing fees (APC) from both Indian and foreign authors for their papers published in the journal.

I seek the views of professionals on the following issue under the Foreign Contribution (Regulation) Act,

2010.

Explanation 3 to the FCRA Act, 2010 appears to provide that fees collected towards services shall not be treated as foreign contribution.