erred in not appreciating that standard and automated cloud computing
services are not taxable as FTS under the Act or the Tax Treaty.
2.2 That ... respectively being amount received as "cloud service fee"
from customers in India towards cloud computing services rendered by the
assessee from outside India
Officer/ld. CIT(A), the ld.
DR has strongly contended that cloud computing services / web hosting
services involve the use of a process because ... facility to use the cloud
computing has effectively led to use of technology driven process by the
end user
other connected was relied to contend that subscription to
the cloud computing services do not give rise royalty income. He also relied the
Mumbai Bench ... 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
Dcit, Circle-4(2), New Delhi vs Campus Eai India Pvt. Ltd., New Delhi on
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
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
2023
engaged in the business of providing Cloud Computing Services to customers
around the world. He submitted, based on proceedings under Section ... Assessing
Officer held that the receipts of the assessee from Cloud Computing Services are
in the nature of Royalty and Fee for Technical Services
