https://www.taxtmi.com/caselaws?id=210400 International connectivity receipts may constitute royalty where dedicated bandwidth and composite telecom arrangements give customers a significant economic and possessory interest in network capacity during the contract period, or consideration is paid for the underlying signal-transmission process. Physical possession of equipment and secrecy of the process are not essential, and split billing does not alter the payment's real character. Substantial local fault resolution, marketing, installation, maintenance and provisioning functions may establish an enduring business connection and support a permanent establishment in India. These factors can attract Indian tax jurisdiction over telecom connectivity income under domestic law and the India-Singapore DTAA. en-us Fri, 07 Jan 2011 00:00:00 +0530 Thu, 09 Feb 2012 10:33:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=210400 International connectivity receipts may constitute royalty where dedicated bandwidth and composite telecom arrangements give customers a significant economic and possessory interest in network capacity during the contract period, or consideration is paid for the underlying signal-transmission process. Physical possession of equipment and secrecy of the process are not essential, and split billing does not alter the payment's real character. Substantial local fault resolution, marketing, installation, maintenance and provisioning functions may establish an enduring business connection and support a permanent establishment in India. These factors can attract Indian tax jurisdiction over telecom connectivity income under domestic law and the India-Singapore DTAA. Case-Laws Income Tax Fri, 07 Jan 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=210400