Receipts from sale of software license being business income is not taxable in India: ITAT Delhi

Tricentis Gmbh Vs DCIT (ITAT Delhi)

ITAT Delhi held that receipts from the sale of software licenses is business income and the same cannot be taxed in India in absence of Permanent Establishment and in terms of India-Austria DTAA.

Facts- The assessee is a non-resident corporate entity incorporated in Austria and a tax resident of Assessee is engaged in the business of providing software quality assurance solutions by selling licenses of its testing software, such as, Tosca, Flood, qTest etc. to various customers across the world, including India. In the ass

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