Receipts from SaaS-based product analytics services rendered to Indian customers were held not taxable as royalty or as fees for technical services/included services under the Act or the India-USA DTAA, because customers only availed services and did not acquire any right to use the assessee's infrastructure, software, or other assets for commercial exploitation. The Tribunal followed jurisdictional High Court and coordinate bench rulings, including Amazon Web Services, and deleted the addition for both assessment years. On TDS credit, the matter was remitted for verification, with directions to allow due credit and recompute interest and allied relief consequentially to the deletion of the substantive addition.
Receipts from SaaS-based product analytics services rendered to Indian customers were held not taxable as royalty or as fees for technical services/included services under the Act or the India-USA DTAA, because customers only availed services and did not acquire any right to use the assessee's infrastructure, software, or other assets for commercial exploitation. The Tribunal followed jurisdictional High Court and coordinate bench rulings, including Amazon Web Services, and deleted the addition for both assessment years. On TDS credit, the matter was remitted for verification, with directions to allow due credit and recompute interest and allied relief consequentially to the deletion of the substantive addition.
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