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
provisions of
Section 194J in respect of the payment for web hosting charges
amounting to Rs. 2.07,500/-. The appellant prays that the conclusion
reached ... being of the considered view that while for the „Web Hosting
Charges‟ of Rs. 2,07,500/-(out of total amount
appellant are as follows:
Ground no. 1: Income from cloud hosting services is erroneously held as royalty
within the meaning of explanation 2 to section ... directions of the Hon'ble DRP erred in holding that cloud
hosting system is combination of hardware, software and networking elements
that constitutes industrial
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
spent on Food Festival in which about 2,000 people were hosted out with pure and simple meal comprising of different types of dishes made ... order of the Commissioner (Appeals), submitted that there was a dinner hosted out by the PATA on 23-1-1978 and it was towards
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
