Consultancy Receipts and Reimbursements Not Taxable as FIS Under India-USA DTAA; "Make Available" Condition Unmet.

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....Income taxable India - taxability of receipts from consultancy services and reimbursement of expenses - characterizing receipts as Fee for Included Services (“FIS”) under Article 12(4)(b) of India - Revenue has not brought on record any materials to establish the fulfillment of make available condition of Article 12(4)(b) of India – USA DTAA. - AT....