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of <h1>Delhi High Court Rules Standard Software Sales Not 'Technical Services' Under India-Ireland DTAA; Requires Evidence of Specialized Knowledge.</h1> The Delhi High Court analyzed the interpretation of 'technical services' under the India-Ireland Double Taxation Avoidance Agreement (DTAA) in a dispute between the Income Tax Department and Salesforce.com Ireland Limited (SFDC Ireland). SFDC Ireland argued that payments from its Indian subsidiary were not 'fees for technical services' as they involved standard software sales, with any technical assistance being incidental. The court found no evidence of customized services or technology transfer, emphasizing that technical services require specialized knowledge application. The court quashed the previous order and remitted the matter for reconsideration, underscoring the need for clear evidence of technical services.
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