2020 (1) TMI 573

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..... . 9 of the order shall now be read as under:- As the facts and circumstances during the year under consideration are same, respectfully following the order of the Tribunal in assessee‟s own case, we do not find any merit in the action of the lower authorities for treating the receipt as fees for technical services despite the concept of make available‟ clause contained in article .....

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..... nical services despite the concept of make available‟ clause contained in article 13(4)(c) of the treaty. Accordingly, the A.O. is directed to delete the addition so made. The aforesaid paragraph has an inadvertent typographical error which is rectified U/s 254(2) of the Income Tax Act, 1961, inasmuch as there is no reference to non-taxability of the amount as equipment royalty a .....

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