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ITAT Deletes FTS Addition as Standard Cybersecurity Software Sales Were Not Technical Services
Case Law Details
- Case Name
- Fireeye Ireland Limited Vs ACIT (ITAT Delhi)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2020-21
- Courts
- All ITAT, ITAT Delhi
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Fireeye Ireland Limited Vs ACIT (ITAT Delhi)
The Delhi Bench of the Income Tax Appellate Tribunal (ITAT) partly allowed the appeals filed by FireEye Ireland Limited for Assessment Years 2020-21 and 2021-22, holding that consideration received from the sale and grant of restricted rights to use standard cybersecurity software products and related support services could not be taxed in India as Fees for Technical Services (FTS).
The assessee, a tax resident of Ireland, was engaged in selling standard cybersecurity software products through restricted user licences or subscriptions, along with re...






