Facts of the Case
The
appellant, Tungsten Automation England Limited, a company incorporated and tax
resident of the United Kingdom, was engaged in providing electronic invoicing
services through its proprietary cloud-based platform. The appellant had
granted a non-exclusive licence to Genpact entities for use of its e-invoicing
platform in respect of overseas end customers. The appellant did not file
returns of income in India for Assessment Years 2016–17 and 2017–18 on the
ground that it had no taxable income in India and no permanent establishment.
The Assessing Officer initiated reassessment proceedings based on information
that payments had been received from Genpact India Private Limited and
concluded that such receipts were taxable in India. Draft assessment orders
treated the receipts as fees for technical services under Section 9(1)(vii) of
the Income Tax Act and Article 13 of the India–UK DTAA. The Dispute Resolution
Panel upheld the view, and the final assessment orders were affirmed by the
Income Tax Appellate Tribunal.
Issues Involved
Whether
the amounts received by the UK entity for providing access to and use of its
e-invoicing platform constituted fees for technical services under Article
13(4)(c) of the India–UK DTAA, whether the “make available” condition was
satisfied, and whether business receipts could be recharacterised as fees for
technical services in the absence of transfer of technical knowledge or skill.
Petitioner’s Arguments
The
appellant contended that the receipts were business income arising from
provision of automated cloud-based services and that no technical knowledge,
skill, know-how, process, or technical design was made available to the Indian
entity. It was argued that Genpact merely used the platform and did not acquire
any capability to independently apply or replicate the underlying technology.
In the absence of a permanent establishment in India, the receipts were not
taxable under the Income Tax Act or the India–UK DTAA.
Respondent’s Arguments
The
Revenue argued that the services rendered were technical in nature and involved
sophisticated technology, and therefore the consideration received qualified as
fees for technical services under Explanation 2 to Section 9(1)(vii) of the Act
and Article 13(4)(c) of the India–UK DTAA. It was contended that the services
enabled Genpact to provide e-invoicing solutions to its customers and thus
satisfied the “make available” requirement.
Court Order / Findings
The
Delhi High Court held that the definition of fees for technical services under
the India–UK DTAA is narrower than under the Income Tax Act and that the treaty
definition would prevail. The Court examined the contractual arrangements and
the nature of services rendered and found that the appellant merely provided
access to its cloud-based platform without transferring any technical
knowledge, skill, know-how, or process. Applying the settled “make available”
test laid down in decisions such as De Beers India Minerals, Guy Carpenter,
Bio-Rad Laboratories, RELX Inc., and IMG UK, the Court held that the services
did not enable the recipient to independently apply the technology in future.
The Court concluded that the receipts could not be characterised as fees for
technical services under Article 13 of the India–UK DTAA.
Important Clarification
The
Court clarified that mere rendering of services using advanced technology or
sophisticated infrastructure does not by itself satisfy the “make available”
condition. For taxation as fees for technical services under the DTAA, there
must be a clear transfer of technical knowledge or skill enabling the recipient
to deploy such technology independently without recourse to the service
provider.
Final Outcome
The
appeals were allowed. The orders passed by the Income Tax Appellate Tribunal,
Dispute Resolution Panel, and the Assessing Officer treating the receipts as
fees for technical services were set aside. It was held that the amounts
received by the appellant from Genpact entities were not taxable in India as
fees for technical services under the India–UK DTAA, and no substantial
question of law survived in favour of the Revenue.
Link to Download Order https://www.mytaxexpert.co.in/uploads/1769497957_TUNGSTENAUTOMATIONENGLANDLIMITEDFORMERLYKNOWNASTUNGSTENNETWORKLIMITEDVsDEPUTYCOMMISSIONEROFINCOMETAXINTERNATIONALTAXATIONCIRCLE311NEWDELHI.pdf
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