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Manpower support service receipts were held not taxable as fees for technical services under Article 12(4)(b) of the India-US DTAA because the services did not make available any technical knowledge, skill, know-how or process. The Tribunal followed its decision in the assessee's own preceding year, noting that the DRP had issued no fresh directions for the year under appeal and that no distinguishing material was shown. Mere facilitation of collaboration with US academic institutions was insufficient to satisfy the make available test, so the addition was deleted.
Manpower support service receipts were held not taxable as fees for technical services under Article 12(4)(b) of the India-US DTAA because the services did not make available any technical knowledge, skill, know-how or process. The Tribunal followed its decision in the assessee's own preceding year, noting that the DRP had issued no fresh directions for the year under appeal and that no distinguishing material was shown. Mere facilitation of collaboration with US academic institutions was insufficient to satisfy the make available test, so the addition was deleted.
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