https://www.taxtmi.com/caselaws?id=446522 Receipts from interconnectivity and international private leased circuit services were treated as non-taxable in India because they did not constitute royalty or fees for technical services. The Tribunal applied earlier co-ordinate bench and jurisdictional High Court rulings, noting that the services were standard telecom services rendered outside India, involved no transfer of rights in equipment or process, gave no right to use equipment, and did not make available technical knowledge, skill, experience, know-how, or processes. The treaty definition was treated as more restrictive and therefore prevailed where beneficial. Section 5(2) was also rejected because the income arose from services performed outside India. en-us Tue, 29 Aug 2023 00:00:00 +0530 Wed, 06 Dec 2023 08:58:12 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=446522 Receipts from interconnectivity and international private leased circuit services were treated as non-taxable in India because they did not constitute royalty or fees for technical services. The Tribunal applied earlier co-ordinate bench and jurisdictional High Court rulings, noting that the services were standard telecom services rendered outside India, involved no transfer of rights in equipment or process, gave no right to use equipment, and did not make available technical knowledge, skill, experience, know-how, or processes. The treaty definition was treated as more restrictive and therefore prevailed where beneficial. Section 5(2) was also rejected because the income arose from services performed outside India. Case-Laws Income Tax Tue, 29 Aug 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=446522