To “make available” technical knowledge, mere provisions of service was not enough and the payer had to...

To “make available” technical knowledge, mere provisions of service was not enough and the payer had to be enabled to perform services himself. The department’s argument that the amendments by the Finance Act, 2012 changes the position is not acceptable, since there is no change in the DTAA between India and USA and the DTAA prevails where it is favourable to the assessee; - AT .....

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