https://www.taxtmi.com/highlights?id=99195 Voice termination service receipts were held not to be royalty or fees for technical services under the Act or the India-USA DTAA because the payment was for a standard telecom service, with no transfer of a right in equipment, intellectual property, or any secret process. The Tribunal followed prior coordinate bench and HC rulings, and held that retrospective domestic amendments broadening "process" could not enlarge the treaty definition of royalty through Article 3(2). The receipts were therefore business profits, and in the absence of a permanent establishment in India, they were not taxable in India. en-us Mon, 27 Apr 2026 08:21:49 +0530 Mon, 27 Apr 2026 08:21:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=99195 Voice termination service receipts were held not to be royalty or fees for technical services under the Act or the India-USA DTAA because the payment was for a standard telecom service, with no transfer of a right in equipment, intellectual property, or any secret process. The Tribunal followed prior coordinate bench and HC rulings, and held that retrospective domestic amendments broadening "process" could not enlarge the treaty definition of royalty through Article 3(2). The receipts were therefore business profits, and in the absence of a permanent establishment in India, they were not taxable in India. Highlights Income Tax Mon, 27 Apr 2026 08:21:49 +0530 https://www.taxtmi.com/highlights?id=99195