The Delhi ITAT held that consideration received by FireEye Ireland for standardised cybersecurity software licences, subscriptions, and related support was not taxable as Fees for Technical Services under the India–Ireland DTAA. Following the jurisdictional High Court’s reasoning, the Tribunal deleted the addition of ₹53.40 crore for AY 2020–21 and applied the same decision to AY 2021–22.
Back
