Facebook India Services Private ... vs Dy. Commissioner Of Income Tax , ... on 19 September, 2022
IN
view that just because the company is providing cloud based
services over various mainframe computers, the company would not be functionally
different as claimed
Bengaluru,6 the case was referred to the TPO for computation of
ALP u/s 92C of the Act with regard to international transactions ... company, the assessee company started its operation in 2015
and offers cloud infrastructure services including providing a
comprehensive set of cloud services. Viz. Assisting
view that just because the company is providing
cloud based services over various mainframe computers, the company
would not be functionally different as claimed
that assessee is engaged in delivering
software-driven cloud networking solutions for large datacentre storage
and computer environments. It also sells its products and services
data centres and space use for
its subscribers over computer network, for example cloud
hosting.
9.11 Besides above, the Noticee has provided a certification
from
Bliq) which is -
comprehensive source of independent research and data.; cloud
solution for Computer system resource for data storage on a common
server
includes
electronic services such as,-
i. advertising on the internet,
ii. providing cloud services;
iii. provision of e-books, movie, music,
software and other intangibles ... information, retrievable
or otherwise, to any person, in electronic
form through a computer network;
v. online supplies of digital content
(movies, television shows, inusic
2784/MUM/2023 (A.Y. 2015-16)
NTT Global Data Centers & Cloud
Infrastructure India Private Limited
liability is ascertained liability and non-payment ... payments of ₹.6,47,09,747/-, brief facts are,
Assessee has availed computers and networking equipment on lease.
The said lease was classified as finance
received was considered for
computing the income. Accordingly income of Rs. 15.10 cr. was
offered on the basis of cloud data of N. Trading Company ... received was considered for computing the income.
Accordingly income of Rs.15.10 cr. was offered on the basis of
cloud data of N. Trading