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    <title>2023 (8) TMI 331 - ITAT DELHI</title>
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    <description>The Tribunal allowed the appeals for both assessment years, holding that payments received for cloud computing services were not taxable in India as royalty or fee for technical services under the Act and the India-USA Double Tax Avoidance Agreement. The Tribunal found that the services provided did not meet the criteria for royalty or FTS/FIS, as they were standard and automated without transfer of intellectual property or technical knowledge to customers. Other tax-related grounds were either not addressed or considered premature.</description>
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      <description>The Tribunal allowed the appeals for both assessment years, holding that payments received for cloud computing services were not taxable in India as royalty or fee for technical services under the Act and the India-USA Double Tax Avoidance Agreement. The Tribunal found that the services provided did not meet the criteria for royalty or FTS/FIS, as they were standard and automated without transfer of intellectual property or technical knowledge to customers. Other tax-related grounds were either not addressed or considered premature.</description>
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