Income accrued in India - tratement of Income from cloud hosting ...

Case Laws Income Tax

February 1, 2021

Income accrued in India - tratement of Income from cloud hosting services as royalty - income from cloud hosting services has erroneously held as royalty within the meaning of explanation (2) to section 9(1)(vi) of the Act as well as Article 12(3)(b) of the Indo-USA DTAA by the AO and DRP. Even otherwise, there is no PE of the assessee in India and hence, no income can be taxed in India in term of Indo-US DTAA. - AT

View Source

← Previous Next →

Income accrued in India - tratement of Income from cloud hosting ...

Case Laws Income Tax

February 1, 2021

You may also like:

Income deemed to accrue or arise in India - The centralised services income, by a reasonable measure, outstrips the royalty income. Thus, rather than centralised service...

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...

Income accrued in India - Taxability of revenue from sale of software - Royalty - The Cloud services merely facilitate the flow of user data from the front end users...

Goa government circular clarifying place of supply for data hosting services provided by Indian service providers to overseas cloud computing service providers. Key...

The circular clarifies the place of supply for data hosting services provided by Indian service providers to overseas cloud computing service providers. It addresses...

Income accrued in India - providing bandwidth services outside India - The assessee company is a tax resident of Singapore, which is providing band width services to the...

Income accrued in India - Taxability of foreign income in India - Royalty receipt - Only difference is that it relates to royalty under India- Switzerland DTAA, and...

The ITAT, an Appellate Tribunal, addressed the issue of whether income deemed to accrue or arise in India through royalty and fees for technical support services. The...

TDS u/s 195 not deducted on payment to Everest Global Inc. for software training services as source of income located outside India and payment made for services outside...

Income deemed to accrue or arise in India - non-resident corporate entity - Taxability of royalty income received by the assessee on subscribers units from original...

Income accrued in India - taxability of receipt towards Infrastructure and Hosting Data Centre (IDC) charges by treating it as royalty - India–Singapore DTAA - the...

The issue pertains to whether the amounts received as sales commission by a non-resident assessee are in the nature of fees for included services, and whether such...

The circular clarifies the place of supply for data hosting services provided by Indian service providers to overseas cloud computing service providers. It addresses...

Income accrued in India - Taxability as Royalty income - the income earned by the assessee from sale of software, either directly to the customers in India or through...

Income deemed to accrue or arise in India - Royalty receipt - All the equipments and machines relating to the service provided by the assessee are under its control and...

Quick Updates: