https://www.taxtmi.com/caselaws?id=433426 Receipts from cloud infrastructure, colocation, mainframe and data recovery services were examined under section 9(1)(vii) read with section 9(2) and the India-USA DTAA. The services were rendered wholly from facilities in the USA, and the record did not show that any technical knowledge, experience, skill, knowhow or process was made available to the recipient. On that basis, the arrangement was treated as provision of infrastructure and processing facilities rather than transfer of technology, so the receipts were not taxable in India as fees for technical services or included services. en-us Thu, 19 Jan 2023 00:00:00 +0530 Mon, 30 Jan 2023 10:20:26 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=433426 Receipts from cloud infrastructure, colocation, mainframe and data recovery services were examined under section 9(1)(vii) read with section 9(2) and the India-USA DTAA. The services were rendered wholly from facilities in the USA, and the record did not show that any technical knowledge, experience, skill, knowhow or process was made available to the recipient. On that basis, the arrangement was treated as provision of infrastructure and processing facilities rather than transfer of technology, so the receipts were not taxable in India as fees for technical services or included services. Case-Laws Income Tax Thu, 19 Jan 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=433426