https://www.taxtmi.com/caselaws?id=781276 Receipts from automated e-invoicing software and related services were held not taxable as fee for technical services because the arrangement did not satisfy the make available test under section 9(1)(vii) of the Income-tax Act or Article 13(4)(c) of the India-UK DTAA; the recipient obtained only access to the platform and user training, not technical knowledge, source code or independent capability to perform the service itself. The computation sheet and consequential demand were remitted for re-examination because the figures required verification. Initiation of penalty proceedings under section 270A was not interfered with, and interest under sections 234A, 234B and 234F was held consequential and not separately disputable. en-us Mon, 10 Nov 2025 00:00:00 +0530 Thu, 13 Nov 2025 08:14:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=781276 Receipts from automated e-invoicing software and related services were held not taxable as fee for technical services because the arrangement did not satisfy the make available test under section 9(1)(vii) of the Income-tax Act or Article 13(4)(c) of the India-UK DTAA; the recipient obtained only access to the platform and user training, not technical knowledge, source code or independent capability to perform the service itself. The computation sheet and consequential demand were remitted for re-examination because the figures required verification. Initiation of penalty proceedings under section 270A was not interfered with, and interest under sections 234A, 234B and 234F was held consequential and not separately disputable. Case-Laws Income Tax Mon, 10 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=781276