https://www.taxtmi.com/caselaws?id=239881 Dedicated international private leased circuit and bandwidth services were treated as royalty under section 9(1)(vi) and Article 12(3) of the treaty, because the arrangement was an integrated end-to-end connectivity facility giving the customer a significant economic interest in the bandwidth and falling within the expanded post-amendment scope covering use of equipment and use of process. The contract could not be split into separate onshore and offshore components, and the treaty definition was read as aligned with the Act. The challenge to interest under sections 234A, 234B and 234D was remanded to the Tribunal for fresh consideration because it had not been examined on merits. en-us Thu, 07 Nov 2013 00:00:00 +0530 Wed, 04 Feb 2026 16:59:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=239881 Dedicated international private leased circuit and bandwidth services were treated as royalty under section 9(1)(vi) and Article 12(3) of the treaty, because the arrangement was an integrated end-to-end connectivity facility giving the customer a significant economic interest in the bandwidth and falling within the expanded post-amendment scope covering use of equipment and use of process. The contract could not be split into separate onshore and offshore components, and the treaty definition was read as aligned with the Act. The challenge to interest under sections 234A, 234B and 234D was remanded to the Tribunal for fresh consideration because it had not been examined on merits. Case-Laws Income Tax Thu, 07 Nov 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=239881