Held that assessee, an Irish company, sold software products to Indian distributors for onward resale to end-users, since receipts were only for acquisition of software product simpliciter, facilitating digital security and not for rendering technical services, such income was not taxable in India as FTS. (AY. 2020-21)
Forcepoint International Technology Ltd. v. ACIT, IT (2025) 215 ITD 165 (Delhi) (Trib.)
S. 9(1)(vii): Income deemed to accrue or arise in India-Fees for technical services-Sale of software products to Indian distributors for onward resale to end-users-Product simpliciter facilitating digital security and not for rendering technical services, such income was not taxable in India as FTS-DTAA-India-Ireland [Art. 12 (3)(b)]
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