https://www.taxtmi.com/caselaws?id=440776 Consideration for Virtual Voice Network connectivity services was treated as payment for a standard telecom facility, not for use of equipment, process or scientific work, so it was not royalty under Article 13(3) of the India-U.K. DTAA. The receipts also did not qualify as fees for technical services under section 9 and the DTAA because no technical knowledge, skill, know-how or process was made available to enable the recipient to perform the service independently, and the facility was automated rather than dependent on constant human intervention. The commentary states that such connectivity charges fall outside both royalty and technical services treatment absent make available or underlying process exploitation. en-us Wed, 19 Jul 2023 00:00:00 +0530 Wed, 29 Jul 2026 10:02:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=440776 Consideration for Virtual Voice Network connectivity services was treated as payment for a standard telecom facility, not for use of equipment, process or scientific work, so it was not royalty under Article 13(3) of the India-U.K. DTAA. The receipts also did not qualify as fees for technical services under section 9 and the DTAA because no technical knowledge, skill, know-how or process was made available to enable the recipient to perform the service independently, and the facility was automated rather than dependent on constant human intervention. The commentary states that such connectivity charges fall outside both royalty and technical services treatment absent make available or underlying process exploitation. Case-Laws Income Tax Wed, 19 Jul 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=440776