https://www.taxtmi.com/caselaws?id=773421 ITAT Delhi held that receipts from data transmission services do not constitute royalty under Article 12(4) of the DTAA with Netherlands. The Tribunal followed consistent precedents from assessment years 2006-07 to 2021-22, ruling that Finance Act 2012 amendments do not affect DTAA provisions. The addition was deleted, confirming that data transmission service income remains outside royalty definition unless DTAAs are jointly amended by both countries. Assessee's appeal was allowed. en-us Fri, 23 May 2025 00:00:00 +0530 Mon, 23 Jun 2025 08:42:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=773421 ITAT Delhi held that receipts from data transmission services do not constitute royalty under Article 12(4) of the DTAA with Netherlands. The Tribunal followed consistent precedents from assessment years 2006-07 to 2021-22, ruling that Finance Act 2012 amendments do not affect DTAA provisions. The addition was deleted, confirming that data transmission service income remains outside royalty definition unless DTAAs are jointly amended by both countries. Assessee's appeal was allowed. Case-Laws Income Tax Fri, 23 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=773421