https://www.taxtmi.com/caselaws?id=790550 Receipts from voice termination and telecom connectivity services were treated as business profits under the India-USA DTAA because they did not involve use of a secret process, right to use equipment, or transfer of intellectual property. The domestic law expansion of "process" in section 9(1)(vi) was not applied to enlarge the treaty meaning of "royalty", and retrospective amendments did not change the DTAA definition. As no permanent establishment existed in India, the receipts were not taxable in India as royalty or fees for technical services and fell outside Indian tax jurisdiction under the treaty. en-us Fri, 17 Apr 2026 00:00:00 +0530 Mon, 27 Apr 2026 08:21:46 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=790550 Receipts from voice termination and telecom connectivity services were treated as business profits under the India-USA DTAA because they did not involve use of a secret process, right to use equipment, or transfer of intellectual property. The domestic law expansion of "process" in section 9(1)(vi) was not applied to enlarge the treaty meaning of "royalty", and retrospective amendments did not change the DTAA definition. As no permanent establishment existed in India, the receipts were not taxable in India as royalty or fees for technical services and fell outside Indian tax jurisdiction under the treaty. Case-Laws Income Tax Fri, 17 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=790550