AWS Cloud Computing Service Receipt Not Taxable as Equipment Royalty: Delhi HC

CIT Vs Amazon Web Services (Delhi High Court) Delhi High Court held that amount received by assessee (Amazon Web Services) from Indian entities for rendering cloud computing services are not taxable as equipment royalty thus the payments received cannot be considered as royalties within the meaning of Article 12(3) of the India-US DTAA. Facts- The Assessee is a company incorporated in the United States of America and is a tax resident of that country. The Assessee had received certain sums of money from Indian entities for rendering cloud computing services, which, according to the AO are char...