Services to power industry at pre-bid stage for independent use satisfies 'make available' test; hel

IT/ILT: Where assessee engaged in providing diverse services to power industry, rendered its consulting and engineering services in relation to ultra mega power projects at a pre-bid stage, in view of fact that assessee's client would use said services, in future alone when bid would be taken up for installation of power project, revenue authorities rightly concluded that assessee received consideration for 'making available' technical services within meaning of article 12 of India-USA DTAA and,