ITAT Delhi Rules DigiCert License Fees Not Taxable as FTS

DigiCert Inc Vs ACIT (ITAT Delhi)

ITAT Delhi order Whether the receipts from Indian resellers for digital certificate licences and related services constitute royalty or fees for technical services (FTS) under the IT Act, 1961 and the India–US DTAA

1. Background and Facts

The assessee, DigiCert Inc, a company incorporated and tax resident in the United States, is engaged globally in the business of issuing and managing digital security certificates (SSL/TLS) that authenticate and encrypt online communications.

During the relevant assessment y

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