https://www.taxtmi.com/caselaws?id=763965 The Tribunal upheld the CIT(A)'s decision, determining that payments made for interconnect services and capacity transfer are not taxable as royalty under the Income Tax Act, aligning with precedents from the Karnataka HC and SC. It concluded that the notice issued under Section 148 was unwarranted, as the payments were not taxable. The Tribunal found no evidence of human intervention or specialized processes to classify the payments as process royalty, thus dismissing the AO's appeal and affirming the CIT(A)'s conclusions on all issues. en-us Fri, 27 Dec 2024 00:00:00 +0530 Tue, 31 Dec 2024 09:05:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=763965 The Tribunal upheld the CIT(A)'s decision, determining that payments made for interconnect services and capacity transfer are not taxable as royalty under the Income Tax Act, aligning with precedents from the Karnataka HC and SC. It concluded that the notice issued under Section 148 was unwarranted, as the payments were not taxable. The Tribunal found no evidence of human intervention or specialized processes to classify the payments as process royalty, thus dismissing the AO's appeal and affirming the CIT(A)'s conclusions on all issues. Case-Laws Income Tax Fri, 27 Dec 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=763965