https://www.taxtmi.com/caselaws?id=442658 The Tribunal ruled in favor of the assessee, determining that inter-connect charges received from Indian telecom operators are not taxable as 'royalty' or 'fees for technical services' under Section 9(1)(vi) & (vii) of the Act or Article 13 of the India-Spain DTAA. These charges are considered business profits taxable in Spain, as there is no permanent establishment in India. The interest under Sections 234A, 234B, and 234C was deemed consequential and required no separate adjudication. Other grounds were either dismissed or considered non-substantial. The appeals were partly allowed, with the main issue resolved in the assessee's favor. en-us Thu, 10 Aug 2023 00:00:00 +0530 Mon, 10 Jun 2024 17:40:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=442658 The Tribunal ruled in favor of the assessee, determining that inter-connect charges received from Indian telecom operators are not taxable as 'royalty' or 'fees for technical services' under Section 9(1)(vi) & (vii) of the Act or Article 13 of the India-Spain DTAA. These charges are considered business profits taxable in Spain, as there is no permanent establishment in India. The interest under Sections 234A, 234B, and 234C was deemed consequential and required no separate adjudication. Other grounds were either dismissed or considered non-substantial. The appeals were partly allowed, with the main issue resolved in the assessee's favor. Case-Laws Income Tax Thu, 10 Aug 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=442658