Sale of Cybersecurity Software Not Taxable as FTSs Under India-Ireland DAA

Forcepoint International Technology Limited Vs ACIT (ITAT Delhi)

ITAT Delhi held that cybersecurity software sale doesn’t not amount to rendering of technical service and hence the same is not taxable as Fees for Technical Services [FTS] under Article 12 of the India-Ireland DTAA and hence not taxable.

Facts-

The assessee company Forcepoint International Technology Limited, Ireland [erstwhile Websense International Technology Limited (WITL)] is an overseas Company. It does not have permanent establishment in India. The present appeal has been filed

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