https://www.taxtmi.com/caselaws?id=310768 ITAT Delhi ruled in favor of the assessee on three issues. First, payments for connectivity services were held not taxable as royalty under India-UK DTAA Article 13, as no equipment was provided by the foreign telecom operator to the assessee. The assessee used its own network for call transmission, distinguishing it from equipment usage scenarios. Second, the tribunal confirmed 100% deduction under Section 80IA from AY 2007-08 to 2011-12, then 30% from AY 2012-13 to 2016-17, following coordinate bench precedent. Third, disallowance of license fee was deleted, noting revenue's inconsistent position without factual or legal changes warranted uniform treatment per judicial precedents. en-us Wed, 23 Mar 2022 00:00:00 +0530 Mon, 13 Nov 2023 11:54:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=310768 ITAT Delhi ruled in favor of the assessee on three issues. First, payments for connectivity services were held not taxable as royalty under India-UK DTAA Article 13, as no equipment was provided by the foreign telecom operator to the assessee. The assessee used its own network for call transmission, distinguishing it from equipment usage scenarios. Second, the tribunal confirmed 100% deduction under Section 80IA from AY 2007-08 to 2011-12, then 30% from AY 2012-13 to 2016-17, following coordinate bench precedent. Third, disallowance of license fee was deleted, noting revenue's inconsistent position without factual or legal changes warranted uniform treatment per judicial precedents. Case-Laws Income Tax Wed, 23 Mar 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=310768