Held that merely because the assessee has a customized landing page, it does not mean that the assessee provides technical services, that too, through human intervention. Even assuming for argument’s sake that the services provided by the assessee are of technical nature, that by itself would not be enough to bring such receipts within the purview of art. 12(4) of the DTAA, unless the make available condition is satisfied. The receipts of the assessee do not qualify as fees for included services under art. 12(4) of India-USA tax treaty.  (AY. 2020-21,  2021-22)