Assessing Officer incorrectly classified all receipts as Fees for Technical Services; 'make available' condition under Article 13(4)(c) not met.

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....Fees for Technical Services (FTS) - The AO himself has stated that some of the services are of the nature of FTS. Thus, AO clearly admits that all the services rendered by the assessee are not in the nature of FTS. In spite of that the AO has treated the entire receipts as FTS and added at the hands of the assessee. - Further, the ‘make available’ condition provided under Article 13(4)(c) remains non-compliant. That being the position, the receipts would not fall within the definition of FTS as provided under Article 13(4) of India – UK DTAA. - AT....