respectively being amount received as "cloud service fee"
from customers in India towards cloud computing services rendered by the
assessee from outside India ... that the cloud computing services provided by the
assessee are merely standard and automated services. The facility of
different category of cloud computing services provided
contended that cloud computing services / web hosting
services involve the use of a process because the facility to use the cloud
computing has effectively ... that there are two broad level
processes involved in cloud computing services. At one level, the process
is to set up the system to deliver
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 ... royalty but merely a consideration for online access of the cloud
computing services for process and storage of data or run the applications.
8.2 While
Dcit, Circle-4(2), New Delhi vs Campus Eai India Pvt. Ltd., New Delhi on
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 ... royalty but merely a consideration for
online access of the cloud computing services for process and storage of
data or run the applications.
7.2 While
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 ... royalty but merely a consideration for
online access of the cloud computing services for process and storage of
data or run the applications.
7.2 While
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 ... royalty but merely a consideration for online access
of the cloud computing services for process and storage of data or run the
applications.
7.2 While
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 ... royalty but merely a
consideration for online access of the cloud computing services for
process and storage of data or run the applications.
7.2 While
2023
engaged in the business of providing Cloud Computing Services to customers
around the world. He submitted, based on proceedings under Section ... assessee from Cloud Computing Services are
in the nature of Royalty and Fee for Technical Services (FTS)/Fee For Included
Services (FIS), hence, chargeable
senior counsel appearing for the assessee
submitted that the assessee provides Cloud Computing Services. He submitted,
in the year under consideration, the assessee had income ... Computing
Services as well as professional and training services. He further submitted,
though, there are several decisions of the Tribunal holding that receipts from
Cloud