https://www.taxtmi.com/caselaws?id=441352 Standard and automated cloud computing services, supplied through a non-exclusive, non-transferable licence, do not amount to royalty where customers receive only access to the service and no right to use or exploit copyright, software, equipment, or dedicated infrastructure. The India-USA DTAA's fees for included services article also does not apply unless technical or consultancy services make available technical knowledge, skill, know-how, or processes; routine support and troubleshooting that merely enable service use do not satisfy that test. On these principles, cloud service receipts are not taxable in India as royalty or as fees for included services. en-us Tue, 01 Aug 2023 00:00:00 +0530 Fri, 05 Jun 2026 14:20:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=441352 Standard and automated cloud computing services, supplied through a non-exclusive, non-transferable licence, do not amount to royalty where customers receive only access to the service and no right to use or exploit copyright, software, equipment, or dedicated infrastructure. The India-USA DTAA's fees for included services article also does not apply unless technical or consultancy services make available technical knowledge, skill, know-how, or processes; routine support and troubleshooting that merely enable service use do not satisfy that test. On these principles, cloud service receipts are not taxable in India as royalty or as fees for included services. Case-Laws Income Tax Tue, 01 Aug 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=441352