EPRSS Prepaid Recharge Services India Pvt.Ltd. v. ITO

100 Taxmann.com 52Reported decision2018#1077 most cited

What is EPRSS Prepaid Recharge Services India Pvt.Ltd. v. ITO authority for?

Payments made for the use of cloud space do not constitute royalty payments for the purpose of Indian income tax, especially when they relate to accessing standard and automated services rather than acquiring rights to copyrighted material.

101

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2019 to 2025.

Also referred to as

EPRSS Prepaid Recharge Services India Pvt.Ltd. v. ITO · 100 Taxmann.com 52 · section 9(1)(vi) · section 195 · royalty · cloud hosting charges · fees for included services · fees for technical services

Issues it is cited on

Judgments citing EPRSS Prepaid Recharge Services India Pvt.Ltd. v. ITO

REASONING GLOBAL E-APPLICATIONS LIMITED,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3(1), HYDERABAD

In the result, appeal filed by the assessee is allowed

ITA 2028/HYD/2017[2012-13]Status: DisposedITAT Hyderabad23 Aug 2022AY 2012-13

Bench: Shri R.K. Panda & Shri K. Narasimha Charyassessment Year: 2012-13 Reasoning Global E- Vs. Dy. C.I.T. Application Ltd, Hyderabad Circle 3(1) Pan:Aadcr6701P Hyderabad (Appellant) (Respondent) Assessee By: Shri Swapnil Deshmukh, Ca Revenue By: Shri Rohit Mujumdar, Dr Date Of Hearing: 07/06/2022 Date Of Pronouncement: 23/08/2022 Order Per R.K. Panda, A.M This Appeal Filed By The Assessee Is Directed Against The Order Dated 27.09.2017 Of The Learned Cit (A)-3, Hyderabad Relating To A.Y.2012-13. 2. Facts Of The Case, In Brief, Are That The Assessee Company Is Engaged In The Business Of Providing It Enabled Electronic Commerce Services. It Filed Its Return Of Income For The A.Y 2012-13 On 30.09.2012 Declaring Loss Of Rs.9,52,71,232/-. During The Course Of Assessment Proceedings, The Assessing Officer Noted That The Assessee Has Debited An Amount Of Rs.1,02,18,116/- Towards Web Hosting Charges. From The Bills/Invoices Produced For The Expenditure So Claimed, The Page 1 Of 19

For Appellant: Shri Swapnil Deshmukh, CAFor Respondent: Shri Rohit Mujumdar, DR
Section 9(1)(vi)

…ITA No 2028 of 2017 Reasoning Global E-Application Ltd Hyderabad आयकर अपील"य अ"धकरण, हैदराबाद पीठ IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘ B ‘ Bench, Hyderabad Before Shri R.K. Panda, Accountant Member AND Shri K. Narasimha Chary, Judicial Member Assessment Year: 2012-13 Reasoning Global E- Vs. Dy. C.I.T. Application Ltd, Hyderabad Circle 3(1) PAN:AADCR6701P Hyderabad (Appellant) (Respondent) Assessee by: Shri Swapnil Deshmukh, CA Revenue by: Shri Rohit Mujumdar, DR Date of hearing: 07/06/2022 Date of pronouncement: 23/08/2022 ORDER Per R.K. Panda, A.M This appeal filed by the assessee is directed aga…

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EPRSS Prepaid Recharge Services India Pvt.Ltd. v. ITO (100 Taxmann.com 52) — Cited in 101 Judgments | BharatTax