The Mumbai Appellate Tribunal recently ruled on a case concerning the taxation of income derived by a foreign company from providing software and equipment used to access the e-portal of the company. The case involved a U.K. company that provides foreign exchange deal match making systems for clients in India. The U.K. company entered into contracts and received payments from the Indian clients for access to the system. The U.K. company also engaged an Indian company to conduct marketing of the system, and to provide the equipment installation and support services to access the deal making system. The taxpayer held...