reasoning.
10.8 So, we hold that the services rendered to foreign
clients qualify as export of services prior to 01.07.2012.
Question No. 3: Whether Rule ... provider.
11.2 In the present case, the services rendered are
digital post-production services such as computer graphics,
digital restoration and reverse telecine, performed
similar issue was considered and the expenditure was
incurred on purchase of computer software were adjudicated as capital in
nature. At the same time ... expenses related to subscription paid towards usage of cloud
13
ITA No.4728/DEL/2024
services or usage of softwares as a service, software licenses
services. Since, local taxes have been levied, it is imperative
that the services have been received and consumed outside
India. Had the services being imported ... 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
reasoning.
10.8 So, we hold that the services rendered to foreign
clients qualify as export of services prior to 01.07.2012.
Question No. 3: Whether Rule ... provider.
11.2 In the present case, the services rendered are
digital post-production services such as computer graphics,
digital restoration and reverse telecine, performed
provision of services of technical or other personnel, but does not include payments for
independent personal services and for dependent personal services as mentioned ... Bliq) which is -
comprehensive source of independent research and data.; cloud
solution for Computer system resource for data storage on a common
server
reasoning.
10.8 So, we hold that the services rendered to foreign
clients qualify as export of services prior to 01.07.2012.
Question No. 3: Whether Rule ... provider.
11.2 In the present case, the services rendered are
digital post-production services such as computer graphics,
digital restoration and reverse telecine, performed
reasoning.
10.8 So, we hold that the services rendered to foreign
clients qualify as export of services prior to 01.07.2012.
Question No. 3: Whether Rule ... provider.
11.2 In the present case, the services rendered are
digital post-production services such as computer graphics,
digital restoration and reverse telecine, performed
2784/MUM/2023 (A.Y. 2015-16)
NTT Global Data Centers & Cloud
Infrastructure India Private Limited
liability is ascertained liability and non-payment ... Appellant in country outside India in
respect of the fees for technical services and thereby subjecting the
same income to double taxation alleging non-submission
company. It is engaged in product engineering services as well as
outsourced product development services. It specializes in the area such
as product design ... providing
software development & consultancy services, engineering services, web
development & hosting, business analytics and BPO services. Likewise,
the ld. DRP also observed that
company. It is engaged in product engineering services as well as
outsourced product development services. It specializes in the area such
as product design ... providing
software development & consultancy services, engineering services, web
development & hosting, business analytics and BPO services. Likewise,
the ld. DRP also observed that
