AWS Service Fees Not Royalty Under Article 12(3) of India-USA DTAA; Not Taxable in India.

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....Income deemed to accrue or arise in India - Taxability of “cloud service fee” received by the assessee from customers in India - the payments received by the assessee from Indian Customer(s) from rendering AWS Services do not qualify as royalty under Article 12(3) of the India-USA DTAA and hence are not taxable in India. - AT....