Mixpanel, Inc. v/s ACIT
Parties Involved
Facts Summary
Mixpanel, Inc. appealed against the final assessment order passed by the ACIT for the Assessment Year 2021-22. The primary issues were whether software licensing and professional services such as installation of software into customer systems amount to Fee for Included Services under Article 12(4)(b) of India-US DTAA. The appeal was allowed as it was determined that the services did not constitute Fee for Included Services.…
Decision in favour of
Assessee
Legal Issues
- 1. Whether software licensing amounts to Fee for Included Services under Article 12(4)(b) of India-US DTAA.
- 2. Whether professional services such as installation of software into customer systems amount to Fee for Included Services under Article 12(4)(b) of India-US DTAA.
Judgment Outcome
Decided in favour of Assessee.
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