Delhi HC directs issuance of Nil tax deduction certificate to SFDC Ireland

SFDC Ireland Limited Vs Commissioner Of Income Tax & Another (Delhi High Court) Summary: The Delhi High Court recently addressed a dispute between SFDC Ireland Limited, a tax resident of Ireland under the India-Ireland Double Taxation Avoidance Agreement (DTAA), and the Indian Income Tax Department. SFDC Ireland provides Customer Relationship Management (CRM) software products to Indian customers through its reseller, SFDC India. The primary issue was whether SFDC Ireland’s income from this arrangement is taxable in India and if a Nil Tax Deduction at Source (TDS) certificate could b...