Sum received for providing support services taxable as FTS if it satisfied make available clause: ITAT

INTERNATIONAL TAX: Where assessee a US based company had entered into a global agreement with its group entities (affiliates), including its Indian subsidiary for provision of support activities in area of supply chain, human resources, strategic planning and marketing, finance and information systems and from nature and duration of contract it was evident that services had been utilized by Indian Company as well and concept of make available which requires that fruits of services should remain

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