https://www.taxtmi.com/caselaws?id=447438 ITAT Bangalore held that interconnectivity utility charges (IUC) received by non-resident assessee from Indian customers cannot be taxed as royalty or fees for technical services under Section 9(1)(vi)/(vii) or India-France DTAA. The tribunal found that providing telecom services through overseas equipment does not constitute granting use or right to use equipment, following Karnataka HC decision in Vodafone Idea Ltd. The charges constitute business profits taxable in resident country, not India, as no permanent establishment exists. Revenue's appeal dismissed. en-us Fri, 22 Dec 2023 00:00:00 +0530 Mon, 25 Dec 2023 15:13:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=447438 ITAT Bangalore held that interconnectivity utility charges (IUC) received by non-resident assessee from Indian customers cannot be taxed as royalty or fees for technical services under Section 9(1)(vi)/(vii) or India-France DTAA. The tribunal found that providing telecom services through overseas equipment does not constitute granting use or right to use equipment, following Karnataka HC decision in Vodafone Idea Ltd. The charges constitute business profits taxable in resident country, not India, as no permanent establishment exists. Revenue's appeal dismissed. Case-Laws Income Tax Fri, 22 Dec 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=447438