Special Leave Petitions challenging TDS under Section 195 on non-resident interconnectivity payments denied; withholding obligation upheld SC dismissed the Special Leave Petitions challenging TDS u/s 195 on payments to non-resident operators characterized as interconnectivity charges, ...
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Special Leave Petitions challenging TDS under Section 195 on non-resident interconnectivity payments denied; withholding obligation upheld
SC dismissed the Special Leave Petitions challenging TDS u/s 195 on payments to non-resident operators characterized as interconnectivity charges, treating them as neither royalty nor FTS nor business profits for the purpose contested. The Court followed its prior orders in analogous matters and refused relief to the petitioners, leaving the impugned tax treatment and withholding obligations intact.
"Delay condoned." In view of the orders dated 26.07.2024 in SLP (C) Dy. No. 24154/2024 [Deputy Director of Income Tax & Anr. vs. M/s Vodafone Idea Ltd.] and 06.12.2024 in SLP (C) Dy. No. 48545/2024 [The Deputy Commissioner of Income Tax, International Taxation vs. M/s Deutsche Telekom AG], "these Special Leave Petitions also stand dismissed." Pending application(s), if any, are directed to stand disposed of. The dismissal is expressly by reference to and on the basis of the earlier pronouncements in the cited SLPs.
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