India ('NPCI'); mobile phone/ mobile banking transactions;
transactions by hosted providers such as FSSNeT, AGS, Prizm, TCPSL, C-
edge, Euronet, FIS, ElectraCard ... middleware between the
devices on the one side and the core banking host of the bank on the other.
The customer transactions would emanate from
influences and that measurement of these services can effectively be divided into Host (H) Network (N), and Customer Premises (P) components.
The goal is that ... that emphasis be placed on Prime Times.
5.1.1. Global Regional and Market:
- Host and Network functions are classified as being Global, Regional or Market based
which is connected with the Airlines on-line inventory systems (the Airlines host) located across the globe, processes the request and sends the result which ... selects the flight and places a request for booking with the Airlines host which is routed through the mainframe of the appellant. The Airlines host
submits that this company is in
divergent high end services like web hosting, email services, spam filtering,
domain names and DNS hosting, web hosting, email ... services, spam
filtering, domain names and DNS hosting is also providing web design
services, domain management services and email management services
which cannot be compared
income of the foreign enterprise attributable to the permanent establishment in the host country. The income attributable to the permanent establishment in the host country ... income attributable to foreign company's operations in the host country, which, in turn, implies the income attributable to the activities carried
assessee submits that the appellant
has entered into Infrastructure and Hosting Data Centre (IDC) agreements
with its Indian group companies and has received revenues from ... agreement the appellant essentially provides IT
infrastructure management and mail box/website hosting services to its
Indian group companies and these IDC services are performed
assessee is against the
order of DRP holding income from cloud hosting services as royalty
within the meaning of explanation 2 to section ... raised the following grounds:-
"Ground no. I: Income from cloud hosting
services is erroneously held as royalty within the
meaning of explanation
Godaddy India Domains Income Tax, Circle-
Circle-1(3)(1),
& Hosting Services
Services Pvt.Ltd., International Taxation,
Unit 003, Tower 4A, New Delhi ... declaring income of
`20,42,77,864/- being the receipt from web hosting services/on
demand sale. The assessee offered the same as income from
confirming the
learned AO's decision of disallowing payment towards web hosting
charges to Amazon Web Services LLC (USA) amounting ... erred in law and on facts
in holding that payment towards web hosting charges to Amazon Web
Services LLC (USA) amounting
agreements with various Airlines
[„Participating Carrier Agreement] by providing interconnectivity between the
host computer of the individual Airline and the Amadeus CRS created ... ADIT
ITA No. 1494/Del/2011
(Assessment Year: 2006-07)
carriers host computer mainframe located at the Airlines head offices. The
reservations are made/ finalized
