Cloud Subscriptions Payments to Non-Resident Suppliers Not Royalties: Delhi HC

CIT (International Tax)-1 Vs Goto Technologies Ireland Unlimited Company (Delhi High Court)

Delhi High Court has dismissed an appeal filed by the Commissioner of Income Tax (CIT), upholding the Income Tax Appellate Tribunal’s (ITAT) decision that subscription payments received by Goto Technologies Ireland Unlimited Company for providing cloud services are not taxable as royalties. This ruling reinforces a consistent judicial stance on the characterization of such digital payments under Indian tax law and Double Taxation Avoidance Agreements (DTAAs).

The appeal by the R

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