https://www.taxtmi.com/caselaws?id=314141 Receipts from telecommunication connectivity and bandwidth services supplied from outside India were held not to constitute royalty under section 9(1)(vi) of the Income-tax Act or Article 12(3) of the India-Singapore tax treaty. Applying the assessee's earlier years' rulings, supported by Delhi High Court authority in New Skies Satellite and the Supreme Court in Engineering Analysis, the ruling reaffirmed that data transmission connectivity services do not amount to royalty, and the Finance Act 2012 amendment did not change the treaty position for the relevant years. The Assessing Officer's additions were deleted and the assessee succeeded. en-us Wed, 13 Jul 2022 00:00:00 +0530 Mon, 20 May 2024 18:36:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=314141 Receipts from telecommunication connectivity and bandwidth services supplied from outside India were held not to constitute royalty under section 9(1)(vi) of the Income-tax Act or Article 12(3) of the India-Singapore tax treaty. Applying the assessee's earlier years' rulings, supported by Delhi High Court authority in New Skies Satellite and the Supreme Court in Engineering Analysis, the ruling reaffirmed that data transmission connectivity services do not amount to royalty, and the Finance Act 2012 amendment did not change the treaty position for the relevant years. The Assessing Officer's additions were deleted and the assessee succeeded. Case-Laws Income Tax Wed, 13 Jul 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=314141