https://www.taxtmi.com/caselaws?id=791033 Payments to a non-resident for leased circuit or internet-related facilities were analysed under Section 9(1)(vi) and the Finance Act, 2012 explanations, with the Court holding that those later explanations could not be applied retrospectively to expand the meaning of royalty for earlier assessment years. On that basis, facility-use payments to a non-resident did not become royalty merely because the recipient was outside India, absent the relevant taxable nexus. No tax deduction obligation arose under Section 195 on that characterisation, and the issue was decided in favour of the assessee. en-us Thu, 30 Apr 2026 00:00:00 +0530 Tue, 05 May 2026 09:09:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=791033 Payments to a non-resident for leased circuit or internet-related facilities were analysed under Section 9(1)(vi) and the Finance Act, 2012 explanations, with the Court holding that those later explanations could not be applied retrospectively to expand the meaning of royalty for earlier assessment years. On that basis, facility-use payments to a non-resident did not become royalty merely because the recipient was outside India, absent the relevant taxable nexus. No tax deduction obligation arose under Section 195 on that characterisation, and the issue was decided in favour of the assessee. Case-Laws Income Tax Thu, 30 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=791033