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7.2 While dealing with similar que stion in regard to the case of M/s. Salesforce.com Singapo re Pte . (supra) whe re the said assessee was pro vide r of comprehensive customer relatio nship management servicing to its customer by using Cloud Computing Services / Web Casting Service s, the Bench in its o rde r date d 25.03.2022 held as under :
"28. Conside ring the facts of the case in totality, in light o f the Maste r Subscription Agreement, we are of the considere d view that the custo mers do not have any access to the process o f the se rvice provider i.e. the assessee, and the assessee does no t ITA No . 312/De l/2021 Microsoft Regio nal S ales Pte Ltd. Ne w Delhi 10 have any access exce pt o therwise pro vided in the master subscription agreement to the data of the subscribe r.