GlobalTech Inc., a company incorporated in the USA, has global assets worth 50 crores and Indian assets worth 25 crores. Its turnover during the…

GlobalTech Inc., a company incorporated in the USA, has global assets worth 50 crores and Indian assets worth 25 crores. Its turnover during the P.Y. 2024-25 is US $ equivalent to 90 crores. Out of 10 board meetings held during F.Y. 2024-25, only 4 were held in India. However, key management and commercial decisions for the conduct of the company's business as a whole were made in India at these meetings. Innovate Ltd., an Indian company, intends to remit fees for technical services to GlobalTech Inc. for providing services in relation to a project in India. Assume such fees is not paid under an agreement approved by the Central Government. Determine the residential status of GlobalTech Inc. for the P.Y. 2024-25. Whether tax is required to be deducted on fees for technical services paid by Innovate Ltd. If yes, at which rate (ignore surcharge and cess)?