Court Rules on TDS Section 195: Technical Services Not Automatically Classified as Royalty Without 'Make Available' Clause.

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....TDS u/s 195 - Royalty - providing of services to use of equipment and right to use equipment - There mere fact that there were certain technical inputs or that the assessee immensely benefited from these services, even resulting in value addition to the employees of the assessee, is wholly irrelevant. The expression ‘make available’ has a specific meaning - AT....