https://www.taxtmi.com/caselaws?id=391619 Cloud hosting receipts were treated as hosting and ancillary services, not royalty, because customers did not obtain possession, control, or operating rights over the equipment; the treaty definition of royalty was applied as written and was not expanded by a retrospective domestic amendment. The same receipts were also not fees for technical services, as the arrangement was a standard hosting service and did not involve technical, managerial, or consultancy services under the treaty. Interest under section 234B was not chargeable to a non-resident where tax was deductible at source by the payer. The additions and interest levy were therefore deleted, granting relief on all substantive issues. en-us Thu, 28 Nov 2019 00:00:00 +0530 Sat, 01 Feb 2020 14:41:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=391619 Cloud hosting receipts were treated as hosting and ancillary services, not royalty, because customers did not obtain possession, control, or operating rights over the equipment; the treaty definition of royalty was applied as written and was not expanded by a retrospective domestic amendment. The same receipts were also not fees for technical services, as the arrangement was a standard hosting service and did not involve technical, managerial, or consultancy services under the treaty. Interest under section 234B was not chargeable to a non-resident where tax was deductible at source by the payer. The additions and interest levy were therefore deleted, granting relief on all substantive issues. Case-Laws Income Tax Thu, 28 Nov 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=391619