https://www.taxtmi.com/caselaws?id=756120 Receipts from overseas bandwidth and connectivity services were treated as non-royalty because the customers obtained only telecommunications services through the provider's own infrastructure, without dominion, possession or effective control over any process or equipment. The article also states that domestic amendments expanding the meaning of "process" in section 9(1)(vi) cannot be imported into a DTAA through Article 3(2) where royalty is already defined in the treaty, as unilateral statutory changes do not alter the negotiated treaty meaning. OSS/GBSA arrangements were likewise characterised as reciprocal service contracts for seamless connectivity and single billing, not as leases or licences of infrastructure, process or equipment. en-us Wed, 24 Jul 2024 00:00:00 +0530 Fri, 26 Jul 2024 12:22:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=756120 Receipts from overseas bandwidth and connectivity services were treated as non-royalty because the customers obtained only telecommunications services through the provider's own infrastructure, without dominion, possession or effective control over any process or equipment. The article also states that domestic amendments expanding the meaning of "process" in section 9(1)(vi) cannot be imported into a DTAA through Article 3(2) where royalty is already defined in the treaty, as unilateral statutory changes do not alter the negotiated treaty meaning. OSS/GBSA arrangements were likewise characterised as reciprocal service contracts for seamless connectivity and single billing, not as leases or licences of infrastructure, process or equipment. Case-Laws Income Tax Wed, 24 Jul 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=756120