Payment for use of disk space is not royalty

Atos Origin IT Services Singapore Pte Ltd. Vs. Asst. Director of Income Tax (ITAT Mumbai)- Assessee who was tax resident of Singapore had entered into a hubbing agreement for providing data processing support to Standard Chartered Bank (SCB) a non resident company engaged in the business of banking in India. Assessee receive amount from SCB India for use of disc space along with embedded software in the hardware of the assessee at its data center in Singapore of the infrastructure of the assessee, whether CIT(A) was justified in treating the income earned by the assessee was of the nature of r...