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
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
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
districts
on account of expenses incurred for the same for
hosting these matches.
ii) Re-imbursement/subsidy from BCCI:- Amount received
towards expenses incurred ... 2017-
M/s Punjab Cricket Association, Mohali
6
same by hosting matches of Punjab franchisee 'King, XI, Punjab' during
the Indian Premier League
raised the following grounds: -
"Ground no. 1: income from cloud hosting services is erroneously held as
royalty within the meaning of explanation ... Dispute Resolution Panel
("DRP") erred in holding that cloud hosting system is combination of
hardware, software and networking elements that constitutes industrial
/ commercial
time could be 25.02.2006 02:02:21 AM,
as per the host/ system date time ... disk marked 'Q' on 19.02.2010
08.46.11 PM, as per the host/ system
date time settings.
3. The file properties of the Microsoft
Excel
assets taken over by the Appellant.
4.0 Disallowance of SMS and server hosting charges
4.1 That on the facts and in the circumstances ... Learned CIT(A) erred in upholding the disallowance of server
hosting charges and SMS purchase charges amounting to Rs. 1,66,90,240
under section
received by the Appellant from customers for
managed hosting services as income chargeable to income tax in India.
2. b. That on the facts ... that the income earned by the Appellant from customers for
providing managed hosting services constituted consideration for use or
right to use equipment
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) and Peer-1 amounting
working under the scheme. The BOAT (NR), Kanpur was
identified as the host of the Nodal Center (NTMIS) at Kanpur and was the
Drawing ... MHRD along with list of staff recommended for
being adjusted in the Host Organizations. The names of the present
applicants find place in the list
