Cloud Service Payments Not Royalty: Tax Authorities Lose Appeal on Income Classification Under DTAA Article 12(3)

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....The HC dismissed the Revenue's appeal, finding no substantial question of law. The court relied on previous judgments regarding cloud service subscription payments, specifically holding that such receipts do not constitute "royalty" income under Article 12(3) of the India-Ireland DTAA and Section 9(1)(vi) of the Income Tax Act, 1961. The decision aligns with prior rulings in similar cases, effectively rejecting the Revenue's contentions and upholding the ITAT's original determination in favor of the Assessee.....