therein who was a resident of USA
was engaged in providing cloud computing infrastructure and
licensing of software to its Indian clients through subscription
agreement ... interpreting it
as licensing of the right to use the above Cloud Computing
Infrastructure and Software (pare 10.5 of the Ld. AO order)
Thus
therein who was a resident of USA
was engaged in providing cloud computing infrastructure and
licensing of software to its Indian clients through subscription
agreement ... interpreting it
as licensing of the right to use the above Cloud Computing
Infrastructure and Software (pare 10.5 of the Ld. AO order)
Thus
Dcit, Circle-4(2), New Delhi vs Campus Eai India Pvt. Ltd., New Delhi on
business of providing enterprise-
wide solutions across multiple industries, ERP, cloud computing, custom
software development, off-shore engineering services, designing,
architecting developing and maintenance ... providing diversified services
including enterprise solutions and IT enabled services, viz., cloud
computing cannot be said to be comparable with the assessee providing
SWD services
business of providing enterprise-wide
solutions across multiple industries, ERP, cloud computing, custom
software development, off-shore engineering services, designing,
architecting developing and maintenance ... providing diversified services
including enterprise solutions and IT enabled services, viz., cloud
computing cannot be said to be comparable with the assessee providing
SWD services
exploit any of the Assessee's IPRs.
The provision of cloud computing services does not entail placing any
hardware at the exclusive disposal ... skill, knowledge,
technology or process to its customers. The cloud computing models
indicate that the Assessee has developed an infrastructure and permits
the customers
other connected was relied to contend that subscription
to the cloud computing services do not give rise royalty income. The Ld
DR supported the findings ... interpreting it as licensing of the right to use the above Cloud
Computing Infrastructure and Software (para 10.5 of the Ld. AO order).
Thus
other connected was relied to contend that subscription
to the cloud computing services do not give rise royalty income. The Ld
DR supported the findings ... interpreting it as licensing of the right to use the above Cloud
Computing Infrastructure and Software (para 10.5 of the Ld. AO order).
Thus
My Space Inc. vs Super Cassettes Industries Ltd. on 23 December, 2016
Bench: S. Ravindra
also
include hosting services, e-commerce merchants,
social networking sites, cloud computing services,
mobile hosts etc. Under the ECD, to maintain
immunity, the ISP must
