Wherever under the DTAA’s. Make available clause is found, then ...
Case Laws Income Tax
March 21, 2016
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
View Source