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
Activities in the areas of business
intelligence, mobile payments, testing automation, cloud
computing etc. According to the Ld. Counsel, the company being
functionally dissimilar, cannot
computing
related services; which services relate to private cloud, desk top
virtualization, cloud migration, hybrid cloud migration, server
management, etc.
(ii) It fails the service ... submitted to contend that it renders services like Virtualization Cloud
Computing, Infrastructure Management and IT modernization services.
IT(TP)A No.3068/Bang/2018
Page
exclude M/s. Infosys BPO Limited as
comparable company while computing the ALP in the ITes
Segment."
• Bombay High Court in case of Pentair ... ITeS and Infrastructure management.
Infrastructure management services of Microland include cloud
computing solutions, application management services, tool-based
disaster recovery environment management services
investments in four thrust
product as enunciated in AS areas: Cloud computing, analytics,
2. Appellant has not submitted 17, Safe harbour rules and enterprise mobility
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
M/S Informatica Business Solutions P ... vs Deputy Commissioner Of Income Tax, ... on 25 April
services and products was available. We find
that cloud computing has been the major source of revenue of this
company, hence, functionally not comparable ... including intellectual
property led software solutions and software products focusing on cloud
computing, business intelligence and analytics etc. and is hence
functionally dissimilar. The company
life
cycle services.
The company is building. IP portfolio which includes Cloud
computing, BI & Analytics, Collaboration and Mobility .
Revenue of Co. is both from
third party vendors.
Functions related to niche functions like SAS and cloud computing are wholly
carried out of the CDS. The main activities carried
