Royalties/fees for technical services – Certification services : Where services rendered to assessee, Indian company, for product certification by non-resident entities, which included evaluating technical quality and issuing certificates, did not fall under definition of FTS as per section 9(1)(vii) and, therefore, assessee was not liable to withhold tax under section 195 – Deputy Commissioner of Income-tax v. Elitecore Technologies (P.) Ltd. – [2024] 164 taxmann.com 571 (Ahmedabad – Trib.)