Sale of software not containing any element of service not fall under FTS

SoftwareONE Pte. Ltd. Vs ACIT (ITAT Delhi)

Introduction: This case involves appeals filed by the assessee challenging final assessment orders under sections 143(3) and 144C(13) of the Income-tax Act, 1961, for the assessment years 2018-19 and 2019-20. The primary dispute in these appeals pertains to the taxability of amounts received from the sale of software as fees for technical services (FTS) under Article 12(4) of the India-Singapore Please become a Premium member. If you are already a Premium member, login here to access the full content.