Saturday International Tax Gyan!! #taxmadeeasy #taxinpic
Enrichment of service recipient/Addition to his capabilities sans transfer of skill/technology will not satisfy “make available” clause, and hence is not taxable as FTS under DTAA (NTT Asia Pacific Holdings Pte Ltd. V/s Assistant Commissioner of Income-tax, Circle 2(1)(2)[2022] 141 taxmann.com 137 (Mumbai – Trib.))
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