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of <h1>Special Leave Petitions challenging TDS under Section 195 on non-resident interconnectivity payments denied; withholding obligation upheld</h1> <h3>The Deputy Commissioner of Income Tax Versus M/s. Deutsche Telekom AG</h3> SC dismissed the Special Leave Petitions challenging TDS u/s 195 on payments to non-resident operators characterized as interconnectivity charges, ... TDS u/s 195 - Royalty or FTS or business profits - payment made to NTOs is towards interconnectivity charges - HELD THAT:- Following the order by this Court in M/s Vodafone Idea Ltd [2024 (10) TMI 601 - SC ORDER] as well as order M/s Deutsche Telekom AG [2024 (12) TMI 1621 - SC ORDER] these Special Leave Petitions also stand dismissed. '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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