Addition towards cloud based services, not a royalty, not sustainable

MOL Corporation Vs ACIT (ITAT Delhi)

Held that the authorities fallen in error in considering the subscription received towards cloud serviced to be royalty income

Facts-

The assessee alleged that the authorities below have failed to appreciate functional aspect of cloud base service while holding subscription to cloud base service as royalty and the additions made by A.O. Contrary to the India USA DTAA.

Conclusion-

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