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Showing contexts for: cloud computing services in Servicenow Nederland Bv, Netherland vs Acit, Circle- Int. Taxation 3(1)(2), ... on 3 March, 2023Matching Fragments
Captioned application has been filed by the assessee seeking stay on recovery of outstanding demand of Rs.15,97,11,535.
SA No. 106/Del./2023
2. Shri Ajay Vohra, learned senior counsel appearing for the assessee submitted that the assessee provides Cloud Computing Services. He submitted, in the year under consideration, the assessee had income from Cloud Computing Services as well as professional and training services. He further submitted, though, there are several decisions of the Tribunal holding that receipts from Cloud Computing Services are not in the nature of priority, however, the Assessing Officer ignoring the decisions of the Tribunal has treated the receipts as royalty. Thus, he submitted, the assessee has a strong prima facie case.