The  assessee rendered business support services to its Indian AE and claimed that amount received for said services would not be taxable in India. Assessing Officer  held that assessee provided training which enabled service recipient to make use of technical knowledge, experience, skills, know-how etc. on its own without depending on assessee  and  held that make available clause was satisfied and receipts were to be treated as FTS as per section 9(1)(vii) and article 12(4) of DTAA.  DRP confirmed order of Assessing Officer. Held that    mere incidental benefit or enrichment which might add to capabilities of service recipient would not be sufficient to satisfy make available clause when critical factor of transfer of skills or technology was not satisfied.  therefore, Assessing Officer was directed to exclude amount received from assessee’s taxable income. (AY. 2017-18)