https://www.taxtmi.com/caselaws?id=799775 Telecommunication and bandwidth service receipts are analysed as business profits rather than royalty or fees for technical services under domestic law and the India-UK tax treaty. Payments for bandwidth services do not constitute royalty where treaty royalty definitions, materially alike across the relevant treaties, do not cover those services. A domestic-law expansion of royalty, including Explanation 6 to section 9(1)(vi), cannot be imported into a treaty without bilateral amendment. Accordingly, the receipts remain business profits and are not taxable in India where no permanent establishment exists. en-us Wed, 16 Sep 2026 00:00:00 +0530 Sat, 26 Sep 2026 08:31:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=799775 Telecommunication and bandwidth service receipts are analysed as business profits rather than royalty or fees for technical services under domestic law and the India-UK tax treaty. Payments for bandwidth services do not constitute royalty where treaty royalty definitions, materially alike across the relevant treaties, do not cover those services. A domestic-law expansion of royalty, including Explanation 6 to section 9(1)(vi), cannot be imported into a treaty without bilateral amendment. Accordingly, the receipts remain business profits and are not taxable in India where no permanent establishment exists. Case-Laws Income Tax Wed, 16 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=799775