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29. The assessee reliance on the Commissioner of Income-tax, International Taxation -1 vs. Amazon Web Services, Inc and Commissioner of Income-tax, International Taxation vs. RELX Inc (supra) doesn't help the cause of the assessee as facts are distinguishable. In the case of Amazon, the facts were that the assessee provided standardized and automated computing services/AWS services Nunhems Netherlands [A.Y 2021-22] to its customer around the globe. The hon'ble Court, interpreting the Indo-USA DTAA, held that consideration for grant of access to standard and automated facilities, of the 'right to use' scientific equipment is not 'royalty' under Article 12(4)(a) of the India-US DTAA. It also held that grant of such service does not entail transfer of any technical know-how, skill, knowledge or process and that the customers of the Assessee do not acquire any right to commercially exploit any of the Assessee's IPRs. The provision of cloud computing services does not entail placing any hardware at the exclusive disposal of the customer.