Wherever under the DTAA’s. Make available clause is found, then as there is no imparting, the payment in...

Wherever under the DTAA’s. Make available clause is found, then as there is no imparting, the payment in question is not ‘FTS’ under the Treaty and when there is no ‘FTS’ clause in the treaties, the payment falls under Article 7 of the Treaty and is business income. - AT .....

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