Hel that no material was found brought on record by the Assessing Officer to establish that during the rendition of services, the assessee had made available technical know-how, skill, etc., to the service recipient so as to enable him to apply technical knowledge, know-how, skill, etc., in the future independently, without the aid and assistance of the assessee. Moreover, in the final assessment orders, the Assessing Officer had not made any discussion under article 12(4) of the Double Taxation Avoidance Agreement between India and Singapore to tax a part of the receipts. Addition is deleted.(AY.2018-19, 2019-20)