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Showing contexts for: cloud computing in Amazon Web Services India Pvt Ltd & Anr. vs Income Tax Officer & Anr. on 31 August, 2023Matching Fragments
10. Accordingly, the AO held that the reseller fees paid by AWS India to AWS USA would fall outside the scope of Equalisation Levy and would be chargeable as business income under the provisions of the Act.
11. In view of the conclusion that AWS USA provides cloud computing services through infrastructure in the form of regions, availability zones, data centres located in India, which constitute its PE in India; the AO held that the payments made by AWS India to AWS USA were attributable to its PE in India.