https://www.taxtmi.com/caselaws?id=442635 The Tribunal held that payments received by a non-resident company for interconnectivity utility charges were not taxable as royalty under Section 9(1)(vi) of the Income Tax Act or the Double Taxation Avoidance Agreement (DTAA). The Tribunal ruled that the payments constituted business profits and were not subject to tax in India due to the absence of a permanent establishment. The appeals were partly allowed in favor of the assessee, with the order pronounced on 31st August 2023. en-us Thu, 31 Aug 2023 00:00:00 +0530 Tue, 05 Sep 2023 13:24:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=442635 The Tribunal held that payments received by a non-resident company for interconnectivity utility charges were not taxable as royalty under Section 9(1)(vi) of the Income Tax Act or the Double Taxation Avoidance Agreement (DTAA). The Tribunal ruled that the payments constituted business profits and were not subject to tax in India due to the absence of a permanent establishment. The appeals were partly allowed in favor of the assessee, with the order pronounced on 31st August 2023. Case-Laws Income Tax Thu, 31 Aug 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=442635