Assessee, a UK based company, which is engaged in business of providing information technology related services to financial payments industry.  During year, assessee had earned revenue from Indian customers on account of sale of software (Prime) license fee and fee for provision for other related services.  Assessing Officer held that receipts on account of fee for provision for other related services constituted fees for technical services (FTS) within meaning and scope of article 13(4)(c) of India-UK DTAA. Department had not brought any evidence on record to substantiate that make available condition was satisfied in case of assessee. Tribunal held that   software itself was not taxable, ‘Fees for provisions for other related services’ will also not be taxable. Addition is deleted.  (AY. 2020-21)