following :-
"the receipts of INR 29,49,01258/- from
provisions of cloud hosting services are also in
the nature of royalty within the meaning ... incorporated and a tax resident of USA. The
assessee is managed cloud computing company and providing services
to its customers on payment of monthly fees
Software Development Company,
having special expertise in emerging technologies such as Cloud computing
business intelligence, etc. Therefore, the same cannot be compared with the
assessee ... Software Development
Company, having special expertise in emerging technologies such as Cloud
computing business intelligence, etc. Although, it is involved in diversified activities
submits that the assessee-company
provides IT Solutions like managed hosting, cloud computing,
collocation, Network connectivity and IT consulting supported by
assessee's global
said company provides services like data analytics, applications,
business processes, cloud computing, consulting, digital, eco energy,
information management, infrastructure services, Internet Of Things
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
purpose of
determining full value of sale consideration for the purpose of computation
of capital gains under sec. 48 of the Act. It is well ... should not be any
cloud of doubt that s. 50C has application only to the extent determining
sale consideration for computation of capital gain under
Dialogic Networks (I) P.Ld, Pune vs Asst Cit Cir 3(3), Mumbai on 27
from AHIPL for provision of ICS is in
relation to use of computer software and/or for the use of process or
for rendering ... that as per the said Explanation transfer of right to use a
computer software would come within the purview of royalty as per
section
deduction for the expenditure incurred should
be given to the assessee while computing undisclosed income. We
have considered this argument also ... doubting the
expenditure, then all the receipts mentioned therein also comes
under cloud of doubt. It is an accepted principle of interpretation of
documents that
Project management services and balancing Cognitive strength of human
mind and computing power of Machine to its clients.
33.7 Cygnet Infotech ... services provided by
Cygnet pertains to blockchain, Artificial Intelligence, Robotic process
Automation, Cloud, Internet of Things, Tax Technology, Augmented / Virtual
Reality, Digital Transformation, Content Management
