This case note summarizes the recent ruling by the Authority for Advance Rulings in Akamai Technologies Inc. that payments received by a foreign company from its Indian subsidiary for a content delivery solution to accelerate online content and business processes under a services reseller agreement were not in the nature of fees for technical services or royalties under the Income-tax Act, 1961 or the India-United States Income Tax Treaty (1989), and that the arrangement did not create a permanent establishment of the foreign company in India.