Tribunal held that Service rendered by AE to assessee was as per agreement according to which services provided by AE to assessee were in nature of assistance in troubleshooting, isolating problem and diagnosing related trouble and alarms and equipment repair services wherein, equipments would be shipped to US by assessee as and when required. It was agreed between parties that AE would be providing such services remotely and noon-site support services would be provided to customers of assessee. Services rendered by AE does not satisfy ‘make available’ requirement as per Article 12(4). Hence, revenue received by AE in view of services rendered to assessee’s customer was not taxable in India as per Article 12(4) of India-US DTAA, applicability of S. 195 was not applicable hence no disallowances can be made. (AY. 2012-13, 2013-14, 2014-15)