Opportunity to furnish unsecured-loan confirmations is required before reassessment initiation; proceedings require fresh consideration after taxpayer...
Under-reporting on a first reassessment return attracts penalty, while enhanced misreporting penalty requires proof of a statutory misreporting catego...
HC held that cloud computing services provided by a US-based company to Indian entities do not constitute royalty or fees for technical services (FTS). The services involve granting non-exclusive, non-transferable access to standard automated cloud infrastructure without transferring any skill, knowledge, technology, or intellectual property rights. Customers merely access standardized services without controlling or commercially exploiting the underlying hardware and software. The payments received are for service usage, not for the right to use scientific equipment or IPR. Consequently, the amounts are not taxable as royalty under the Income Tax Act or the India-US Double Taxation Avoidance Agreement.
HC held that cloud computing services provided by a US-based company to Indian entities do not constitute royalty or fees for technical services (FTS). The services involve granting non-exclusive, non-transferable access to standard automated cloud infrastructure without transferring any skill, knowledge, technology, or intellectual property rights. Customers merely access standardized services without controlling or commercially exploiting the underlying hardware and software. The payments received are for service usage, not for the right to use scientific equipment or IPR. Consequently, the amounts are not taxable as royalty under the Income Tax Act or the India-US Double Taxation Avoidance Agreement.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4915 
