Condition of ‘make available’ not satisfied hence technical service not taxable: ITAT Delhi

Invesco Holding Company (US) Inc. Vs ACIT (ITAT Delhi) ITAT Delhi held that the condition of make available was not satisfied for services when provided by assessee did not enabled the AEs to apply the technology independently. Thus, technical service provided to AEs not taxable. Facts- The Assessee is a tax resident of the USA and provides Information Technology (“IT”) Application services, IT Infrastructure services and IT security (“IT services”) to its AEs globally including the ones present in India. The holds Tax Residency Certificate (“TRC”) and claim...