https://www.taxtmi.com/caselaws?id=774995 The SC dismissed a Special Leave Petition concerning TDS provisions under section 195 regarding payments to non-resident telecom operators for interconnectivity charges. The case involved whether such payments constituted royalty, fees for technical services, or business profits under DTAA provisions. The HC had previously ruled that assessees are entitled to DTAA benefits, and the ITAT's position that DTAA cannot be considered in proceedings under section 201 was upheld. The court determined that since facilities were located outside India and the agreement was with a Belgium entity having no Indian presence, Indian tax authorities lacked jurisdiction over income from extra-territorial sources. Following the precedent in Vodafone Idea Ltd., the SC dismissed the petition, disposing of all pending applications. en-us Mon, 14 Jul 2025 00:00:00 +0530 Thu, 17 Jul 2025 08:19:12 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=774995 The SC dismissed a Special Leave Petition concerning TDS provisions under section 195 regarding payments to non-resident telecom operators for interconnectivity charges. The case involved whether such payments constituted royalty, fees for technical services, or business profits under DTAA provisions. The HC had previously ruled that assessees are entitled to DTAA benefits, and the ITAT's position that DTAA cannot be considered in proceedings under section 201 was upheld. The court determined that since facilities were located outside India and the agreement was with a Belgium entity having no Indian presence, Indian tax authorities lacked jurisdiction over income from extra-territorial sources. Following the precedent in Vodafone Idea Ltd., the SC dismissed the petition, disposing of all pending applications. Case-Laws Income Tax Mon, 14 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=774995