The assessee  earned revenue from an Indian group company (IHG India) on account of management support costs. Based on the nature of services enumerated under the support service agreement with IHG India, the assessee provided operational support, accounting and legal support, information technology related services etc. The Assessing Officer made addition for management support charges to the income of the assessee as fees for technical services (FTS) under the provisions of the India-Singapore tax treaty. CIT (A) confirmed the order of the Assessing Officer. On appeal the Tribunal held that support services in relation to operational, accounting, training and recruitment etc. would not be regarded as services which was ‘make available’ and accordingly, not taxable as ‘fees for technical services’ under article 12(4) of India-Singapore tax treaty. (AY. 2012-13)