Rendering cloud computing services not liable to tax in India as royalty or FTS/FIS

Amazon Web Services Vs ACIT (ITAT Delhi) ITAT Delhi held that rendering cloud computing services/ Amazon Web Services (AWS Services) cannot be held to be liable to tax in India either as royalty or as Fees for Technical Services (FTS)/ Fees for Included Services (FIS). Facts- The assessee is a foreign company and a tax resident of USA. The assessee provides ‘standard and automated’ cloud computing services /AWS services to its customers around the globe. It is alleged that payment received by the assessee from Indian customers amount to Rs. 2,47,68,23,222/- and Rs. 1007,81,05,172/- is liab...