https://www.taxtmi.com/caselaws?id=399630 Bandwidth connectivity receipts from Indian customers were analysed under section 9(1)(vi) and Article 12(3) of the India-Singapore tax treaty. The service involved standard connectivity over a network controlled by the provider, and the customer obtained only a service, not possession, control, or economic exploitation of equipment or process. Because the treaty definition of royalty had not been enlarged by the domestic-law amendment, the treaty text remained controlling and the receipts were not taxable as royalty. On the advance-tax issue, interest under section 234B was held not leviable for a non-resident taxable, if at all, only under the treaty framework. en-us Wed, 30 Sep 2020 00:00:00 +0530 Tue, 16 Dec 2025 16:48:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=399630 Bandwidth connectivity receipts from Indian customers were analysed under section 9(1)(vi) and Article 12(3) of the India-Singapore tax treaty. The service involved standard connectivity over a network controlled by the provider, and the customer obtained only a service, not possession, control, or economic exploitation of equipment or process. Because the treaty definition of royalty had not been enlarged by the domestic-law amendment, the treaty text remained controlling and the receipts were not taxable as royalty. On the advance-tax issue, interest under section 234B was held not leviable for a non-resident taxable, if at all, only under the treaty framework. Case-Laws Income Tax Wed, 30 Sep 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=399630