https://www.taxtmi.com/caselaws?id=771971 Payments for standardised cloud computing services were analysed under the royalty and fees-for-technical-services provisions of the Income-tax Act and the India-US DTAA. The court noted that customers received only a limited right to access automated cloud services, without possession, control, or commercial exploitation rights over the underlying hardware, software, or intellectual property, so the receipts were not royalty or equipment royalty. It also held that support services merely helped customers use the platform and did not make technical knowledge, skill, know-how, or processes available, so the receipts were not fees for technical services or included services. The Tribunal's view that no substantial question of law arose was affirmed. en-us Thu, 29 May 2025 00:00:00 +0530 Fri, 05 Jun 2026 14:23:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=771971 Payments for standardised cloud computing services were analysed under the royalty and fees-for-technical-services provisions of the Income-tax Act and the India-US DTAA. The court noted that customers received only a limited right to access automated cloud services, without possession, control, or commercial exploitation rights over the underlying hardware, software, or intellectual property, so the receipts were not royalty or equipment royalty. It also held that support services merely helped customers use the platform and did not make technical knowledge, skill, know-how, or processes available, so the receipts were not fees for technical services or included services. The Tribunal's view that no substantial question of law arose was affirmed. Case-Laws Income Tax Thu, 29 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=771971