Held that the assessee, a UK-based company, provided IT support services to its Indian AE, since there was no transfer of any technical knowledge, experience, skill, know-how or process that would enable AE to use them and thus, the ‘make available’ clause was not satisfied, the amount received by assessee was not taxable as FTS. Assessee, a UK resident, rendered non-IT support services to its Indian AE, and there was no transfer of technical knowledge, skill or process enabling AE to use them and, thus, the ‘make available’ clause under Article 13 of India-UK DTAA was not satisfied, receipts could not be taxed as FTS. (AY. 2022-23)