Income Accrued in India u/s 9(1)(vii) and India-USA DTAA Involves "Make Available" Requirement for FTS.

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....Income accrued in India - FTS - Section 9(1)(vii)/DTAA with India-USA - service relates to supply chain Human Resources, Strategic Planning and marketing, Finance and information systems - the concept of make available requires that the fruits of the services should remain available to the service recipients in some concrete shape such as technical knowledge, experience, skills etc. which is met in the instant case as can be reflected from the nature and duration of the contract - FTS....