Royalties/Fees for technical services – Others : Where assessee made payment to foreign agencies for services rendered abroad , since none of payee had permanent establishment in India and provisions of DTAA, being more beneficial to assessee, would apply in preference to provisions of Act, no disallowance could be made under section 40(a)(i) – Express Publications (Madurai) (P.) Ltd. v. Deputy Commissioner of Income-tax – [2024] 161 taxmann.com 453 (Chennai – Trib.)