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Decision of coordinate bench of this Tribunal in the case of
Amazon Web Services, Inc. [TS-419-ITAT-2023(DEL)]
wherein it was held that the payments made for cloud
computing / AWS services, which inter alia includes cloud
hosting, is not taxable as FTS / FIS under the provisions of
the Act read with India-USA DTAA. The Tribunal concluded
that the AWS services provided by the assessee are
standardized services that do not provide any technical
services to its customers nor satisfy the 'make available'
test as the customer will not be able to make use of the
technical knowledge, skill, process etc. used by the
assessee in providing cloud services by itself in its
business or for its own benefit without recourse to the
assessee in future.