https://www.taxtmi.com/caselaws?id=462783 Mere subscription-based access to a cloud software application does not amount to royalty or fee for technical services where no copyright, equipment use, or technical knowledge enabling the customer to apply the technology is transferred. On materially identical facts, the Tribunal followed its earlier decisions and the Jurisdictional High Court's ruling, holding that the treaty provisions on royalty and consultancy or technical services were not attracted. The CRM service receipts were therefore not taxable in India under the Income-tax Act or the applicable treaty. en-us Fri, 17 May 2024 00:00:00 +0530 Mon, 14 Jul 2025 16:00:41 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=462783 Mere subscription-based access to a cloud software application does not amount to royalty or fee for technical services where no copyright, equipment use, or technical knowledge enabling the customer to apply the technology is transferred. On materially identical facts, the Tribunal followed its earlier decisions and the Jurisdictional High Court's ruling, holding that the treaty provisions on royalty and consultancy or technical services were not attracted. The CRM service receipts were therefore not taxable in India under the Income-tax Act or the applicable treaty. Case-Laws Income Tax Fri, 17 May 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=462783