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of <h1>SLPs dismissed: Interconnectivity payments to non-resident telecom operators by ILD licensee not taxable under Section 195</h1> <h3>The Deputy Commissioner of Income Tax (International Taxation) Versus M/s. M.I. Limited</h3> The Deputy Commissioner of Income Tax (International Taxation) Versus M/s. M.I. Limited - TMI Delay condoned. Special Leave Petitions disposed of by following orders dated 26.07.2024 (Deputy Director of Income Tax & Anr. v. M/s Vodafone Idea Ltd.), 17.03.2025 (Deputy Commissioner of Income Tax & Ors. v. M/s Singapore Telecommunications Ltd.), and 23.05.2025 (The Commissioner of Income Tax (International Taxation) & Anr. v. M/s Communication Global Network Services Ltd.). Court extracted and relied on the order in Vodafone Idea, which noted a delay of 222 days and observed that the petition was 'covered by the judgment of this Court in Engineering Analysis Centre of Excellence Private Limited vs. Commissioner of Income Tax and Anr. reported in (2022) 3 SCC 321.' It rejected the contention that a pending Review Petition justified later filing, referring to the Explanation to Order XLVII Rule 1, CPC. The Vodafone Idea order further noted a three-Judge Bench dismissal of related Review Petitions in The Commissioner of Income Tax vs. GE India Technology Private Limited etc. and concluded: 'The Special Leave Petition is dismissed on merits following the aforesaid judgment/order.' Pending applications stand disposed of.
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