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of Income taxable in India - Taxability of the receipts as “Royalty' - telecom services comprising of interconnectivity services - Once the situs is outside India, then in order to determine whether the payments made by a resident of India to a non resident involves element of income is to be examined u/s 9 and in the present case, the Assessing Officer has examined the applicability of section 9(1) (vi) & 9(1)(vii) i.e. the payments involve royalty as well as fee for technical services. - Revenue appeal dismissed - AT
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