Whether a tax resident of Singapore, taxable for sale of computer software in terms of the India-Singapore DTAA?


Quick Summary
This case concerns whether a Singapore tax resident company, distributing computer software in the Asia Pacific region, is liable for tax in India on its software sales to Indian distributors and end-users. The company argued it had no physical presence in India and received payments outside the country, therefore not subject to Indian taxation. The Income Tax Appellate Tribunal ultimately allowed the appeal of the assessee.

Court :
ITAT Bnagalore

Brief :
This is an appeal by the assessee against the final Order of Assessment dated 14.07.2017 by the DCIT(International Taxation), Circle � 1(1), Bengaluru, passed under section 143(3) r.ws. 144C(5) of the Income Tax Act, 1961 (hereinafter called �the Act�), relating to Assessment Year 2014-15.

Citation :
IT(TP)A No.1861/Bang/2017

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