Salary paid to seconded employees doesn’t ‘make available’ any technology; No FTS arises under India

IT/ILT: Expatriation of employees under seconded agreement without transfer of technology would not fall under term make available as per article 13(4)(c) of Indo-UK DTAA, and therefore, payment made by assessee towards salary expenditure of employees deputed to assessee under seconded agreement could not be considered as fees for technical services