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Cloud Hosting Income Not Taxed as Technical Services u/s 9(1)(vii) or Article 12(4)(a) Indo-US DTAA.

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....Income from cloud hosting services as fee for technical services within the meaning of Section 9(1)(vii) of the Act as well as fee for included services under Article 12(4)(a) of the IndoUS DTAA - cannot be taxed as FTS....

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