No Royalty on sale of software & no Fees for Technical Services on back-office services

M/s. QlikTech International AB Vs DCIT (ITAT Bangalore) Bangalore ITAT rules out royalty on distribution of software and holds that software payments are not taxable in India by placing reliance on landmark rulings in case of Engineering Analysis Centre of Excellence. It further held that back office services don’t qualify as Fees for Technical Services under India-Sweden tax treaty by invoking the benefit of the ‘a contained India Portugal DTAA and India-US DTAA. FULL TEXT OF THE ORDER OF ITAT BANGALORE This is an appeal by the assessee is directed against the order dated 25.2.2021of CIT(...