India-USA DTAA: "Make Available" Clause Requires Recipient to Retain Tech Skills Post-Contract for Independent Use.

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....Income deemed to accrue or arise in India - FTS under the India-USA DTAA - provision of information technology and other administrative services - In order to invoke make available clauses, technical knowledge and skill must remain with the person receiving the services even after the particular contract comes to an end and the technical knowledge or skills of the provider should be imparted to and absorbed by the receiver so that the receiver can deploy similar technology or techniques in the future without depending upon the provider. - AT....