ACIT,
C/o Go Daddy India Domains and Circle 1(3)(1),
Hosting Services P. Ltd., International Taxation,
st
1 Floor, 01A167, Wework New Delhi ... engaged in the business of providing facilitation of
domain name registration, web hosting, web designing, SSL certification and
other services. The nature of the services
agreement, the appellant, essentially
provides IT infrastructure management and mailbox/website hosting services
to its Indian group companies; these IDC services are performed ... agreement comprise of
administration and supervision of central infrastructure; mailbox hosting
services and website hosting services, (iv) IDC services ensure 100% uptime
for critical external
Daddy India Delhi
Domains and Hosting
Services Private Limited
01A167,First Floor, We
Work Bristol Chowk, Platina
Tower, MG Road, Sector -
28, Gurgaon
(APPELLANT) (RESPONDENT ... erred in holding
that the Appellant's receipts from web hosting, sale of on
demand products, web designing, SSL certification
services etc. amounting
ACIT,
C/o Go Daddy India Domains and Circle 1(3)(1),
Hosting Services P. Ltd., International Taxation,
st
1 Floor, 01A167, Wework New Delhi ... engaged in the business of providing facilitation of
domain name registration, web hosting, web designing, SSL certification and
other services. The nature of the services
India and
implemented through ICAR. All the SMS irrespective of their host
institution KVKs, possess the same qualification, are recruited through
identical selection process, perform ... legitimate pay
scale to the applicants on the basis of controlling/host institution violates
the rights guaranteed to the applicants under Article
unanimity
between the parties that they relate to data center and mailbox hosting
services. What is meant by mailbox hosting services? It is a service ... assessee is required to
provide storage services for email and datacenter hosting. Similarly, for project
related services to Standard Chartered Bank, the scope of services
Royalty‟.
GROUND II: OBJECTION AGAINST ADDITION ON ACCOUNT OF INCOME FROM
WEB HOSTING SERVICES
Page | 2
PDR Solutions FZC
ITA no.1855/Mum./2022 ... Assessing Officer
('AO') erred in proposing that income from web hosting services is taxable as
'Royalty under Section 9(1Xvi
debited an amount of
Rs.1,02,18,116/- towards web hosting charges. From the
bills/invoices produced for the expenditure so claimed, the
Page ... letter dated
28. 10.2014 submitted that the assessee company
has paid Web Hosting charges to Amazon Web
Services LLC, a USA based company
erred in holding that the web hosting services
provided/rendered by the Appellant are taxable as Fee for Technical
services under Section ... erred in not appreciating that the Appellant has characterized
income from web hosting services as royalty and already offered the same
from the owner of the database, it avails facilities like
webhosting/cloud hosting services, data, bandwidth, link connectivity as
also various services such as legal ... Payments for
software license fee, access to various online databases, web hosting,
cloud computing, cloud space hiring, access of hardware access through
software, access
