Fee for technical services

I didn't get it but this might be useful for you

Explanation to 9 (1)vii.—For the removal of doubts, it is hereby declared that for the purposes of this section, income of a non-resident shall be deemed to accrue or arise in India under clause (v) or clause (vi) or clause (vii) of sub-section (1) and shall be included in the total income of the non-resident, whether or not,—

 (i)  the non-resident has a residence or place of business or business connection in India; or

(ii)  the non-resident has rendered services in India.

then this will not be taxable in India in the hands of service provider