Assessee, a U.K. based company, provided services to its AE, BTPL under Business Cooperation Agreement. Services rendered by assessee to BTPL did not satisfy ‘make available’ clause as envisaged under article 13(4)(c) to fall within scope of FTS, since assessee did not make available any technical knowledge, experience or skill to BTPL. Services were continuously rendered by assessee to BTPL and BTPL had to again and again go back to assessee for provision of these services. BTPL was in no way able to apply and use technical knowledge provided by assessee on its own in its business. Twin test of rendering services and making technical knowledge available at same time were not satisfied.  Therefore, fees for services rendered by assessee from outside India to BTPL were not in nature of FTS as per provisions of article 13(4)(c) of India-UK DTAA. Not liable to deduct tax at source.  (AY. 2017-18)