facts were that the assessee
provided standardized and automated computing services/AWS services
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ITA No. 3382/DEL/2023
Nunhems Netherlands ... exploit any of the Assessee's IPRs.
The provision of cloud computing services does not entail placing any
hardware at the exclusive disposal
right of reproduction. The services
are provided online via data centre located outside India. The Cloud
services merely facilitate the flow of user data from ... royalty but merely a
consideration for online access of the cloud computing services for
process and storage of data or run the applications
diversified markets. Thus, the services
rendered by the company are not functionally comparable to the routine
SWD services rendered by the assessee.
16. We find ... service
management services, integrated Information Technology ('IT') service
management Software as a Solution, business process management
implementation services, cloud computing, consulting, enterprise
integration
appointed assessee as non-exclusive seller of standard &
automated cloud computing services etc as discussed above in
this order. Assessee is also doing Marketing
repro duction. The services are provide d
online via data centre located o utside India. The Cloud
services merely facilitate the flo w of user ... comprehensive customer
relatio nship management servicing to its customer by using
Cloud Computing Services / Web Casting Service s, the
Bench
products and renders aftermarket
service management services, integrated IT service management
solution, business process management implementation services,
cloud computing, consulting, enterprise integration, geographical
information system ... development service segment and is
providing services in the field of data and analytics, cloud and
mobile computing. He submitted that the company was rejected
revenues primarily from software
services and software products
- Segmental details not available in Financial Statements (Details
of software products and services)
Bodhtree Consulting ... website, the company is into product
engineering, provision of analytics and cloud computing services.
b. Abnormal profit making company
• Company operates on a different pricing
relation to commercial relationship between Google and Truecaller through
Google cloud computing services and Ad services, it has been stated that none of the
arrangements ... relation to commercial relationship between Google and Truecaller through Google
cloud computing services and Ad services, Google has stated that none of the
arrangements contain
also provides services in financial services and insurance,
manufacturing, energy utilities communications and services and
retail, consumer packaged foods, logistics and life services.
Further ... with that of assessee, as it is involved
in providing cloud computing related services and provides high
end ITES services. Ld.AR also submitted that
Infosys BPO Limited as
comparable company while computing the ALP for the ITeS
Services.
4.2 On the issue of Segmental margins to be considered ... services of M/s
Microland is that it engaged in ITeS and Infrastructure management.
Infrastructure management services of Microland include cloud
computing solutions, application management
