Held that the  manpower support required from assessee by TTL India was only of two personnel and, thus, assessee provided technical or consultancy services through its two employees which were consumed in provision of services itself and nothing was ‘made available’ to TTL India or TML for afterwards use. The  assessee did not receive any fee for included services under article 12(4) and said fee is  not chargeable  to tax. Held that  the assessee was a distributor of software licenses, who acquired software licenses from third party and sold same to Indian company against certain sum, since said sum was on account of sale of software licenses and not for parting with copyright of software, said amount could not be brought within ambit of Royalties under article 12 of DTAA.  (AY.  2015-16)