https://www.taxtmi.com/caselaws?id=763481 ITAT Delhi held that a non-resident assessee providing cloud-based E-Invoice Portal licensing services to Indian entities is liable to tax in India. The tribunal applied Section 5(2) read with Section 9 of the Income Tax Act, determining that income sourced in India through technical services is taxable under primary source rules. Following GVK Industries SC precedent, income is chargeable where the payer is located. The receipts qualified as fees for technical services under both the Income Tax Act and India-UK DTAA, establishing Indian tax liability for the non-resident service provider. en-us Wed, 18 Dec 2024 00:00:00 +0530 Thu, 19 Dec 2024 19:42:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=763481 ITAT Delhi held that a non-resident assessee providing cloud-based E-Invoice Portal licensing services to Indian entities is liable to tax in India. The tribunal applied Section 5(2) read with Section 9 of the Income Tax Act, determining that income sourced in India through technical services is taxable under primary source rules. Following GVK Industries SC precedent, income is chargeable where the payer is located. The receipts qualified as fees for technical services under both the Income Tax Act and India-UK DTAA, establishing Indian tax liability for the non-resident service provider. Case-Laws Income Tax Wed, 18 Dec 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=763481