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    <title>2023 (7) TMI 1412 - ITAT DELHI</title>
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    <description>Payments for bandwidth services rendered outside India through IPLC/MPLS connectivity were examined as to whether they constituted royalty under section 9(1)(vi) and Article 12(3) of the India-Singapore Tax Treaty. The Tribunal followed its earlier coordinate bench rulings in the assessee&#039;s own case, noting that the factual and legal position for the year was unchanged and that identical receipts had already been held not to be royalty. On that basis, the bandwidth receipts were treated as not taxable as royalty.</description>
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      <link>https://www.taxtmi.com/caselaws?id=314157</link>
      <description>Payments for bandwidth services rendered outside India through IPLC/MPLS connectivity were examined as to whether they constituted royalty under section 9(1)(vi) and Article 12(3) of the India-Singapore Tax Treaty. The Tribunal followed its earlier coordinate bench rulings in the assessee&#039;s own case, noting that the factual and legal position for the year was unchanged and that identical receipts had already been held not to be royalty. On that basis, the bandwidth receipts were treated as not taxable as royalty.</description>
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