https://www.taxtmi.com/caselaws?id=783559 Receipts from international private leased circuit and MPLS bandwidth services were held not to constitute royalty under section 9(1)(vi) of the Income-tax Act or Article 12(3) of the India Singapore Tax Treaty, because the payments were for bandwidth services and not for use of equipment, use of process, or any other royalty element. The Tribunal followed its consistent view in the assessee's own earlier years, as subsequently upheld, and applied that binding line of reasoning to identical facts for the relevant year. The royalty addition was therefore deleted. en-us Fri, 12 Dec 2025 00:00:00 +0530 Tue, 16 Dec 2025 14:47:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783559 Receipts from international private leased circuit and MPLS bandwidth services were held not to constitute royalty under section 9(1)(vi) of the Income-tax Act or Article 12(3) of the India Singapore Tax Treaty, because the payments were for bandwidth services and not for use of equipment, use of process, or any other royalty element. The Tribunal followed its consistent view in the assessee's own earlier years, as subsequently upheld, and applied that binding line of reasoning to identical facts for the relevant year. The royalty addition was therefore deleted. Case-Laws Income Tax Fri, 12 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783559