Applicant provided with exclusive office space as well as on-site space and lockable space for storing tools and equipment, identifiable place of business at its disposal, constitutes permanent establishment therefore income from activity is chargeable to tax in India as business profits .
Organising committee of commonwealth games not acquiring Know-how or ability to use it. “Make Available” clause is not satisfied . Income does not constitute royalty hence income is not taxable as fees for technical services