https://www.taxtmi.com/caselaws?id=769857 Legal Case Summary:SC ruled on tax treatment of bandwidth service payments to overseas telecom providers. The court held that such payments do not constitute "royalty" under Section 9(1)(vi) of Income Tax Act, 1961. The decision affirmed that bandwidth charges represent telecommunication service payments, not intellectual property usage. The court prioritized DTAA beneficial provisions over retrospective domestic tax amendments, emphasizing substance over form in tax interpretation. The Revenue's appeal was ultimately dismissed. en-us Tue, 22 Apr 2025 00:00:00 +0530 Sat, 03 May 2025 14:04:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=769857 Legal Case Summary:SC ruled on tax treatment of bandwidth service payments to overseas telecom providers. The court held that such payments do not constitute "royalty" under Section 9(1)(vi) of Income Tax Act, 1961. The decision affirmed that bandwidth charges represent telecommunication service payments, not intellectual property usage. The court prioritized DTAA beneficial provisions over retrospective domestic tax amendments, emphasizing substance over form in tax interpretation. The Revenue's appeal was ultimately dismissed. Case-Laws Income Tax Tue, 22 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=769857