The Delhi Bench of the Income Tax Appellate Tribunal (ITAT) ruled that payments made by Indian distributors for the sale of cybersecurity software from Forcepoint International Technology Limited, an Ireland-based firm, are not taxable as Fees for Technical Services (FTS) under Indian law or the India-Ireland Double Taxation Avoidance Agreement (DTAA). The Tribunal noted that the transactions involved no human interface or technical services, as the software is sold on a principal-to-principal basis without any rights to modification or personal technical input. This decision reinforces the distinction between software sales and technical services, significantly impacting cross-border software transactions and clarifying tax liabilities for international software firms operating in India.