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Showing contexts for: cloud computing in M/S. Myntra Designs Private Limited, ... vs Deputy Commissioner Of Income Tax ... on 3 September, 2021Matching Fragments
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9. The Ld CIT(A) also held that the payments made for use of software is royalty under the provisions of Income tax Act also. In this regard, the Ld CIT(A) has observed as under:-
"8. I find that the decision of Hon'ble Karnataka High Court in the case of Samsung (supra) is applicable in the facts of the case. Accordingly, the claim that use of software is not royalty within the I T Act is rejected."
Finally, the Ld CIT(A) concluded as under:-
"31. In view of the above, the argument of the appellant that consideration paid for purchase of software, cloud computing, cloud space hiring, (involving transfer of the right to use the software) is not royalty is not acceptable. The grounds in this respect are therefore dismissed."