E-Invoicing Software Solutions provided to Indian Company was taxable as “Fee For Technical Services” (FTS) u/s 5 (2)

Tungsten Network Ltd. Vs DCIT (ITAT Delhi) Conclusion: Income of assessee company had arisen in India as the payer i.e. Genpact India was also situated in India. Therefore, under the primary source rule under section 5(2), the income received by assessee company accrued or arose in India. The process of providing technical services by the assessee and receiving payments having source in India as per above principles deserves to be held liable to tax. Held: Assessee a UK company, provided cloud based e-invoicing software solution and related services. Assessee was granted the right to use this ...