https://www.taxtmi.com/caselaws?id=308989 The ITAT ruled in favor of the assessee, finding that revenue from the sale of software by Microsoft Regional Sales Pte. Ltd. is not taxable as "Royalty" in India under the India-USA Double Taxation Avoidance Agreement. Additionally, the ITAT held that revenue from cloud services is not taxable as "Royalty" and that the subscription fee is payment for access to cloud computing services, not royalty. The issues regarding the transfer of TDS credit, excess interest levied, and penalty proceedings were also addressed by the ITAT in its comprehensive analysis and decision. en-us Wed, 31 Aug 2022 00:00:00 +0530 Fri, 04 Aug 2023 21:24:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=308989 The ITAT ruled in favor of the assessee, finding that revenue from the sale of software by Microsoft Regional Sales Pte. Ltd. is not taxable as "Royalty" in India under the India-USA Double Taxation Avoidance Agreement. Additionally, the ITAT held that revenue from cloud services is not taxable as "Royalty" and that the subscription fee is payment for access to cloud computing services, not royalty. The issues regarding the transfer of TDS credit, excess interest levied, and penalty proceedings were also addressed by the ITAT in its comprehensive analysis and decision. Case-Laws Income Tax Wed, 31 Aug 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=308989