https://www.taxtmi.com/caselaws?id=210400 Receipts from international telecom connectivity may be characterised as royalty where dedicated bandwidth or composite connectivity arrangements confer a significant economic interest in network capacity, and where payment is for use of the underlying telecom process; physical possession of equipment and secrecy of the process are not treated as essential. The article also states that substantial Indian support, provisioning, installation, maintenance, fault resolution and marketing functions may establish business connection and a permanent establishment in India, thereby supporting Indian tax jurisdiction under the Income-tax Act 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 Receipts from international telecom connectivity may be characterised as royalty where dedicated bandwidth or composite connectivity arrangements confer a significant economic interest in network capacity, and where payment is for use of the underlying telecom process; physical possession of equipment and secrecy of the process are not treated as essential. The article also states that substantial Indian support, provisioning, installation, maintenance, fault resolution and marketing functions may establish business connection and a permanent establishment in India, thereby supporting Indian tax jurisdiction under the Income-tax Act and the India-Singapore DTAA. Case-Laws Income Tax Fri, 07 Jan 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=210400