Software License Fees & Related Services Not Taxable as FTS Under India-UK DTAA.

The Income Tax Appellate Tribunal (ITAT) ruled that software license fees and related services such as training, utilization, and installation are not taxable as Fees for Technical Services (FTS) under the India-UK Double Taxation Avoidance Agreement (DTAA). The ITAT upheld the assessee's claim that the software license fees were not taxable, referencing a previous decision that related services cannot be treated as FTS if the software itself is non-taxable. The ITAT found no new evidence to challenge this position and thus removed the addition, favoring the assessee's appeal. .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X