https://www.taxtmi.com/caselaws?id=795439 Software, SaaS and related service receipts require separate analysis from software royalty under Article 12 of the India-Ireland DTAA. Fees for technical services depend on whether the services are specialised, exclusive and specifically sought by customers rather than a standard automated facility uniformly available to users; automation alone is not determinative. Relevant facts include the service's nature, human involvement in training or support, and exclusivity. Where taxability is established, the Article 12 treaty rate of 10% operates as a cap and cannot be increased by surcharge or education cess. en-us Fri, 17 Jul 2026 00:00:00 +0530 Wed, 22 Jul 2026 08:48:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=795439 Software, SaaS and related service receipts require separate analysis from software royalty under Article 12 of the India-Ireland DTAA. Fees for technical services depend on whether the services are specialised, exclusive and specifically sought by customers rather than a standard automated facility uniformly available to users; automation alone is not determinative. Relevant facts include the service's nature, human involvement in training or support, and exclusivity. Where taxability is established, the Article 12 treaty rate of 10% operates as a cap and cannot be increased by surcharge or education cess. Case-Laws Income Tax Fri, 17 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=795439