Bench: Hon’Ble Sri N.V.Vasudevan, Jm & Shri M.Balaganesh Am]
Section 9(1)(vii) Explanation 2, stops with the ‘rendering’ of technical services. The DTAA goes further and qualifies such rendering of services with words to the effect that the services should also make available technical knowledge, experience, skill etc. to the person utilizing the services. The meaning of the expression make available were considered by the Tribunal