https://www.taxtmi.com/caselaws?id=793348 Web hosting receipts were treated as payments for access to standard server space, connectivity and infrastructure, not for use or right to use industrial, commercial or scientific equipment, because the customer had no possession, operational control or dominion over the servers and only limited inspection rights for security verification. The domestic-law expansion of royalty could not enlarge the India-USA DTAA definition without a corresponding treaty amendment, so the receipts were not taxable as royalty. The arrangement also did not make available technical knowledge, skill, know-how or a process, so it did not constitute fees for technical services under the treaty. The Revenue's appeals were rejected. en-us Mon, 01 Jun 2026 00:00:00 +0530 Sat, 13 Jun 2026 08:36:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=793348 Web hosting receipts were treated as payments for access to standard server space, connectivity and infrastructure, not for use or right to use industrial, commercial or scientific equipment, because the customer had no possession, operational control or dominion over the servers and only limited inspection rights for security verification. The domestic-law expansion of royalty could not enlarge the India-USA DTAA definition without a corresponding treaty amendment, so the receipts were not taxable as royalty. The arrangement also did not make available technical knowledge, skill, know-how or a process, so it did not constitute fees for technical services under the treaty. The Revenue's appeals were rejected. Case-Laws Income Tax Mon, 01 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=793348