2025 (6) TMI 1136

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.... ORDER PER ANUBHAV SHARMA, JM: This appeal is preferred by the Assessee against the final assessment order dated 03.12.2019 passed by the Dy. Commissioner of Income-tax, Circle, International Taxation-2(2)(2), New Delhi (hereinafter referred to as the Ld. AO) u/s 144C(13) r.w.s. 143(3) of the Income Tax Act, 1961 (hereinafter referred to as 'the Act') for AY 2016-17. 2. Heard and perused the re....

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.... Tribunal vide decision dated 30.12.2024 has held that income received by the assessee towards domain registration services as per Article 12 of relevant DTAA would not be taxable in India. 3. Similarly, the web hosting services provided to the customers has also been considered by the coordinate bench in the case of the assessee and it is held as follows:- "23. We have considered the rival sub....

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....een defined under the provisions of the Act. We further find that after the insertion of Explanation 5 to section 9(1)(vi) of the Act by Finance Act 2012, the possession or control or location of the right, property, or information is not relevant under the provisions of the Act. However, we find that similar amendment has not been carried out in the provisions of India UAE DTAA. In DIT vs New Ski....