https://www.taxtmi.com/caselaws?id=381455 Bandwidth service payments were held not to constitute royalty or fees for technical services because the recipient obtained no right to use equipment, no access to a process, and no making available of technical knowledge, skill, experience, know-how or process. The later domestic-law expansion of the royalty definition in the Income-tax Act, 1961 did not override the narrower India-Singapore DTAA definition. The receipts were treated as business profits, but they were not taxable in India because the foreign recipient had no business connection or permanent establishment in India under Article 7 of the treaty. en-us Fri, 10 May 2019 00:00:00 +0530 Wed, 29 Apr 2026 11:55:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=381455 Bandwidth service payments were held not to constitute royalty or fees for technical services because the recipient obtained no right to use equipment, no access to a process, and no making available of technical knowledge, skill, experience, know-how or process. The later domestic-law expansion of the royalty definition in the Income-tax Act, 1961 did not override the narrower India-Singapore DTAA definition. The receipts were treated as business profits, but they were not taxable in India because the foreign recipient had no business connection or permanent establishment in India under Article 7 of the treaty. Case-Laws Income Tax Fri, 10 May 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=381455