https://www.taxtmi.com/caselaws?id=310768 Network connectivity charges paid to a non-resident were treated as payment for international connectivity services, not as consideration for the use of equipment, so they were held outside the treaty definition of royalty and not taxable as fee for technical services; the related disallowance under section 40(a)(ia) was deleted. Deduction under section 80IA at 30% of eligible profits was upheld because the existing co-ordinate bench view was followed and no stay order existed. Variable licence fee disallowance was also deleted on the principle of consistency, as the expenditure had been accepted in earlier years and pending SLPs in other matters did not justify a fresh disallowance. 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 Network connectivity charges paid to a non-resident were treated as payment for international connectivity services, not as consideration for the use of equipment, so they were held outside the treaty definition of royalty and not taxable as fee for technical services; the related disallowance under section 40(a)(ia) was deleted. Deduction under section 80IA at 30% of eligible profits was upheld because the existing co-ordinate bench view was followed and no stay order existed. Variable licence fee disallowance was also deleted on the principle of consistency, as the expenditure had been accepted in earlier years and pending SLPs in other matters did not justify a fresh disallowance. Case-Laws Income Tax Wed, 23 Mar 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=310768