Supply of technical designs/drawings- defence of ‘Make Available Clause’ accessible

Buro Happold Limited Vs. DCIT (ITAT Mumbai) Background Nowadays, it is quite normal that multinational companies or companies belonging to same group having international presence share their human resources, experiences, technical knowledge & know how for overall growth and development of the group. From taxability point of view, the consideration paid by the service receiver to the service provider for receipt of such technical services are on continuous radar of the Income Tax Authorities. The tax authorities while analysing this transaction look at the substance of the transaction rath...