Commissioner of Income Tax v. Salesforce.com Singapore Pte. Ltd.

The Commissioner of Income Tax - International Taxation -1 vs. Amazon Web Services, Inc

Bench: HON'BLE MR. JUSTICE VIBHU BAKHRU,HON'BLE MR. JUSTICE TEJAS KARIA

…whether payments for cloud computing are taxable as royalty under the Act and the relevant Double Taxation Avoidance Agreement has been the subject matter of various decisions. 42. In CIT (International Taxation) v. Salesforce.com Singapore Pte. Ltd.: (2024) 465 ITR 257, a coordinate bench of this Court had considered the question whether fees for CRM service provided by the assessee [Salesforce] to businesses and industries would be taxable as royalty under the Act and the India-Singapore Double Taxation Avoidance Agreement. In the said case, Salesforce maintained a CRM platform, access to which was granted to…

The Commissioner of Income Tax - International Taxation -3 vs. Salesforce.Com Singapore Pte. Ltd

Bench: HON'BLE THE ACTING CHIEF JUSTICE,HON'BLE MR. JUSTICE TUSHAR RAO GEDELA

…learned counsel for the revenue states, at the outset, that the aforesaid questions are covered by the decision of this court in Assessee’s own case for the earlier assessment year - Commissioner of Income Tax v. Salesforce.com Singapore Pte. Ltd.: (2024) 465 ITR 257. 5. In view of the above, no substantial question arises for consideration of this court. 6. The appeal is, accordingly, dismissed. Pending application also stands disposed of. VIBHU BAKHRU, ACJ TUSHAR RAO GEDELA, J DECEMBER 12, 2024 M Click here to check corrigendum, if any This is a digitally signed order. The authent…

The Commissioner of Income Tax - International Taxation -3 vs. Salesforce.Com Singapore Pte. Ltd

Bench: HON'BLE MR. JUSTICE TUSHAR RAO GEDELA,HON'BLE THE ACTING CHIEF JUSTICE

…learned counsel for the revenue states, at the outset, that the aforesaid questions are covered by the decision of this court in Assessee’s own case for the earlier assessment year - Commissioner of Income Tax v. Salesforce.com Singapore Pte. Ltd.: (2024) 465 ITR 257. 5. In view of the above, no substantial question arises for consideration of this court. 6. The appeal is, accordingly, dismissed. Pending application also stands disposed of. VIBHU BAKHRU, ACJ TUSHAR RAO GEDELA, J DECEMBER 12, 2024 M Click here to check corrigendum, if any This is a digitally signed order. The authe…

The Commissioner of Income Tax - International Taxation -3 vs. Salesforce.Com Singapore Pte. Ltd

…learned counsel for the revenue states, at the outset, that the aforesaid questions are covered by the decision of this court in Assessee’s own case for the earlier assessment year - Commissioner of Income Tax v. Salesforce.com Singapore Pte. Ltd.: (2024) 465 ITR 257. 5. In view of the above, no substantial question arises for consideration of this court. 6. The appeal is, accordingly, dismissed. Pending application also stands disposed of. VIBHU BAKHRU, ACJ TUSHAR RAO GEDELA, J DECEMBER 12, 2024 M Click here to check corrigendum, if any This is a digitally signed order. The authent…

The Commissioner of Income Tax - International Taxation -3 vs. Salesforce.Com Singapore Pte. Ltd

…learned counsel for the revenue states, at the outset, that the aforesaid questions are covered by the decision of this court in Assessee’s own case for the earlier assessment year - Commissioner of Income Tax v. Salesforce.com Singapore Pte. Ltd.: (2024) 465 ITR 257. 5. In view of the above, no substantial question arises for consideration of this court. 6. The appeal is, accordingly, dismissed. Pending application also stands disposed of. VIBHU BAKHRU, ACJ TUSHAR RAO GEDELA, J DECEMBER 12, 2024 M Click here to check corrigendum, if any This is a digitally signed order. The authe…

The Commissioner of Income Tax - International Taxation -3 vs. Salesforce.Com Singapore Pte. Ltd

…learned counsel for the revenue states, at the outset, that the aforesaid questions are covered by the decision of this court in Assessee’s own case for the earlier assessment year - Commissioner of Income Tax v. Salesforce.com Singapore Pte. Ltd.: (2024) 465 ITR 257. 5. In view of the above, no substantial question arises for consideration of this court. 6. The appeal is, accordingly, dismissed. Pending application also stands disposed of. VIBHU BAKHRU, ACJ TUSHAR RAO GEDELA, J DECEMBER 12, 2024 M Click here to check corrigendum, if any This is a digitally signed order. The authe…

The Commissioner of Income Tax - International Taxation -3 vs. Salesforce.Com Singapore Pte. Ltd

…atia, learned counsel for the revenue states at the outset that the aforesaid questions are covered by the decision of this Court in assessee’s own case for earlier assessment year - Commissioner of Income Tax Vs. Salesforce.com Singapore Pte. Ltd.: (2024) 465 ITR 257. 5. In view of above, no substantial question arise for consideration of This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 27/03/2026 at 12:31:52 this Court. 6. The appeal is accordingly di…