OUTSYSTEMS SINGAPORE PTE. LTD.,SINGAPORE vs. DCIT CIRCLE 2(2)(2) (INTERNATIONAL TAXATION), NEW DELHI

ITA 1601/DEL/2025Status: DisposedITAT Delhi10 December 2025AY 2022-23Bench: SHRI VIKAS AWASTHY (Judicial Member), SHRI M. BALAGANESH (Accountant Member)11 pages
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What did the Tribunal hold?

The Tribunal held that the assessment order, being signed manually in an 'E-Proceedings' case, suffers from an incurable defect and is liable to be quashed. Furthermore, the Tribunal ruled that the software license fees and services do not qualify as FTS.

What were the facts?

The assessee's assessment order was signed manually despite the assessment being conducted through 'E-Proceedings'. The assessee also argued that software license fees and services should not be treated as 'Fee for Technical Services' (FTS) as per the India-Singapore DTAA.

What were the issues?

Whether an assessment order signed manually in an 'E-Proceedings' case is valid, and whether software license fees constitute 'Fee for Technical Services' under the DTAA.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 144C(13)

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Cases cited in this judgment(2)Show list

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Income Tax Appellate Tribunal, DELHI BENCH “D”, DELHI

Hearing: 03/12/2025Pronounced: 10/12/2025

PER VIKAS AWASTHY, JM: This appeal by the assessee is directed against the Assessment Order passed u/s. 143(3) r.w.s. 144C(13) of the Income Tax Act,1961 (hereinafter referred to as ‘the Act’) dated 10.01.2025, for Assessment Year 2022-23. 2. The assessee in appeal has raised as many as 13 grounds. The ld. Counsel for the assessee at the ou

The order continues below.

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