Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Income deemed to accrue or arise in India - Taxability of “cloud service fee” received by the assessee from customers in India - the payments received by the assessee from Indian Customer(s) from rendering AWS Services do not qualify as royalty under Article 12(3) of the India-USA DTAA and hence are not taxable in India. - AT
Income deemed to accrue or arise in India - Taxability of “cloud service fee” received by the assessee from customers in India - the payments received by the assessee from Indian Customer(s) from rendering AWS Services do not qualify as royalty under Article 12(3) of the India-USA DTAA and hence are not taxable in India. - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
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