Clarifying "Make Available" Requirement in TDS Section 195: Service Benefits Must Be Independently Usable by Recipient.

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....TDS u/s 195 - Scope of “make available” - The concept of make available which requires that fruits of services should remain unavailable to the service recipients in some concrete shape such as technical knowledge, experience, skill, etc and service recipient has to make use of such technical knowledge, skill, etc by himself in his business and for his own benefit. - Whereas the facts of the case in hand show that the assessee does not gain any technical knowledge, experience or skill as it is not involved in the process that service provider is following while rendering the services. - AT....