Subscription, professional and training services not FTS hence not taxable: ITAT Delhi

Service Now Nederland BV Vs ACIT (ITAT Delhi) ITAT Delhi held that subscription, professional and training services rendered by the assessee do not fall within the definition of FTS under India-Netherland DTAA and, therefore, cannot be taxed in India. Facts- The case of the assessee was selected for scrutiny assessment. AO observed that assessee had claimed INR 171,92,37,658/- as exempt from taxation under Article 12 of India-Netherlands DTAA. Rejecting the claim of the assessee, the AO taxed INR 171,92,37,658/- as FTS under DTAA. The assessee filed objections against the action of the AO befo...