BCCI Income Deemed Indian Despite Overseas Events; Meets 'Make Available' Criteria Under India-UK DTAA Article 13(4)(c.

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....The source of income of the BCCI is in India and not outside India. Merely because the event is performed outside India it cannot be said that source of income of the BCCI is not in India - receipt of the appellant satisfies the ‘make available‘ test as provided under article 13 (4) ( c) of the India UK DTAA as fees for technical services. - AT....