Imparting training to pilots as per statutory norms doesn't satisfy 'make available' clause; no FTS

IT/ILT: Where assessee engaged in business of charter hire of helicopters, paid training expenses of pilots to a US based company, in view of fact that training was given to pilots and other staff as per requirement of DGCA Rules in order to enable pilots to work in aviation industry and such training would not fall under term 'service make available' as mentioned in para 4(b) of article 12 of India-USA DTAA, assessee was not required to deduct tax at source while making payments in question