Income from management support costs under India-Singapore DTAA not 'made available' per Article 12(4); not independently usable.

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....Income accrued in India - Amount accrued to the Assessee from another group company in India on account of management support costs - FTS under the India- Singapore DTAA - principal and meaning of 'Make Available' - the operational support such as Providing advice, information and competitive expertise to local general CMH Hotel management on the operation of Hotels, which are consistent with the strategic plan can at best be the managerial consultancy service but not the services made available so that the recipient can use or replicate the such services received from the assessee. - the provisions of the Article 12(4) could not be applied to the services rendered by the assessee in the strict sense of the provisions of DTAA. - AT....