The Mumbai Income Tax Appellate Tribunal (ITAT) issued a decision on 29 January 2021 concerning whether payments received from India by a U.S. company for cloud hosting services are taxable as royalties and/or fees for technical services. The case involved a U.S. company, Rackspace U.S., Inc. Rackspace provides cloud hosting services and received income from customers in India, which the Indian assessing officer (AO) held was taxable income in India as royalties for the for use of or right to use industrial/commercial/scientific equipment. The AO also held that the income could be taxable as fees for technical services. In its...