ITAT Bangalore Judgments — June 2023

The Tribunal held that the assessee's services, which involved providing test reports, did not 'make available' technical knowledge to the Indian customers. The customers needed to repeatedly seek the assessee's services and could not independently use the technology, thus the 'make available' condition was not met.

The Tribunal held that the disallowance made under Section 143(1)(a) for employee's contribution to PF/ESI not paid within the due date stipulated in the respective Acts was justified. The assessee's appeals were dismissed.

The Tribunal held that the assessee's services, which involved providing test reports, did not 'make available' technical knowledge to the Indian customers. The customers needed to repeatedly seek the assessee's services and could not independently use the technology, thus the 'make available' condition was not met.