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Consulting services provided by UK based Co. not taxable as FTS as it didn't satisfy make available clause

April 4, 2019[2019] 103 taxmann.com 344 (Mumbai - Trib.)
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IT/ILT: Payment received by assessee a U.K. based company for providing consulting services to an Indian entity will not be considered as fees for technical services under article 13(4)(c) of India-UK DTAA as supply was contract specific and was not made avaialble to Indian entity to be used in any other project in future

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