https://www.taxtmi.com/caselaws?id=756120 Bandwidth and connectivity receipts for services provided through the provider's own overseas infrastructure fall outside royalty treatment where customers receive only telecommunications services, not possession, dominion, effective control, or a right to use equipment or process. Article 12 of the India-Singapore DTAA contains its own royalty definition, so domestic amendments expanding the meaning of "process" under the Income-tax Act cannot be imported through Article 3(2) or alter the treaty bargain. OSS and GBSA arrangements providing reciprocal connectivity and single billing remain service contracts where operators and customers lack exclusive rights over the network infrastructure. 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 Bandwidth and connectivity receipts for services provided through the provider's own overseas infrastructure fall outside royalty treatment where customers receive only telecommunications services, not possession, dominion, effective control, or a right to use equipment or process. Article 12 of the India-Singapore DTAA contains its own royalty definition, so domestic amendments expanding the meaning of "process" under the Income-tax Act cannot be imported through Article 3(2) or alter the treaty bargain. OSS and GBSA arrangements providing reciprocal connectivity and single billing remain service contracts where operators and customers lack exclusive rights over the network infrastructure. Case-Laws Income Tax Wed, 24 Jul 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=756120