Subscription received towards Cloud Services is not royalty income

Microsoft Regional Sales Pte. Ltd Vs ACIT (ITAT Delhi) ITAT Delhi held that cloud services merely facilitates the flow of user data from the front end user through internet to the provider’s system and back. Accordingly, subscription received towards cloud services is not royalty income. Facts- Assessee had filed a return of income declaring Nil income on 31.10.2017 claiming TDS of Rs. 9,28,94,483/- and a revised return declaring the same Nil income claiming TDS of Rs. 9,74,72,239/- was filed on 29.03.2019. AO held the payments made by the users as the consideration for the use or the right ...