https://www.taxtmi.com/caselaws?id=313070 ITAT Bangalore ruled that interconnectivity utility charges received by a Hong Kong tax resident assessee from Indian telecom companies do not constitute royalty under section 9(1)(vi) of the Income Tax Act. The Tribunal held that absent any India-Hong Kong tax treaty, the payments should be analyzed solely under domestic tax law. Following the Vodafone Idea Ltd. precedent, the receipts were characterized as business profits taxable in Hong Kong rather than as fees for technical services or royalty income taxable in India. The appeal was decided in favor of the assessee. en-us Wed, 08 Nov 2023 00:00:00 +0530 Fri, 22 Mar 2024 06:57:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=313070 ITAT Bangalore ruled that interconnectivity utility charges received by a Hong Kong tax resident assessee from Indian telecom companies do not constitute royalty under section 9(1)(vi) of the Income Tax Act. The Tribunal held that absent any India-Hong Kong tax treaty, the payments should be analyzed solely under domestic tax law. Following the Vodafone Idea Ltd. precedent, the receipts were characterized as business profits taxable in Hong Kong rather than as fees for technical services or royalty income taxable in India. The appeal was decided in favor of the assessee. Case-Laws Income Tax Wed, 08 Nov 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=313070