https://www.taxtmi.com/caselaws?id=752856 ITAT Bangalore held that interconnect utility charges (IUC) received by a Hong Kong tax resident from an Indian telecom company do not constitute royalty under section 9(1)(vi) of the Income Tax Act. Following the Vodafone Idea Ltd. precedent, the tribunal determined that payments for telecom interconnection services fall outside the royalty provisions. Since no India-Hong Kong tax treaty existed and revenue failed to establish a permanent establishment in India, the payments were classified as business profits taxable in the recipient's country. Appeal decided in favor of assessee. en-us Thu, 25 Apr 2024 00:00:00 +0530 Sun, 19 May 2024 08:17:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=752856 ITAT Bangalore held that interconnect utility charges (IUC) received by a Hong Kong tax resident from an Indian telecom company do not constitute royalty under section 9(1)(vi) of the Income Tax Act. Following the Vodafone Idea Ltd. precedent, the tribunal determined that payments for telecom interconnection services fall outside the royalty provisions. Since no India-Hong Kong tax treaty existed and revenue failed to establish a permanent establishment in India, the payments were classified as business profits taxable in the recipient's country. Appeal decided in favor of assessee. Case-Laws Income Tax Thu, 25 Apr 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=752856