High Court held that the Subscribers only used services; no equipment/software rights were granted; hence, fees are not taxable in India as royalty/FTS. The Supreme Court dismissed the SLP filed by the Revenue (AY.2010-11 to 2016-17)
CIT (Int) v. Salesforce.com Singapore Pte Ltd(2025) 306 Taxman 95 (SC) Editorial : CIT (Int) v. Salesforce.com Singapore Pte Ltd (2024)165 taxmann.com 580 (Delhi)(HC)
S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-
Subscription fees for remote access to CRM application without any transfer of copyright are not “royalty” under Sec. 9(1)(vi) and not taxable—SLP dismissed-DTAA-India-Singappore. [Art. 12, Art. 136]
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