Roaming Charges Not Classified as Royalty Under India-UK DTAA Article 13(3); VIL Lacked UK Infrastructure.

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....Income taxable in India - cellular roaming charges - India-UK DTAA under Article 13(3) - Royalty - VIL already possessed the process used for providing roaming services and used the same to provide services to customers in India, however, since VIL could not provide services to its customers who travelled to UK and it does not have any facility or infrastructure in UK and for this, even the arrangement with the assessee was made to provide services to its customers whenever they travel to UK. - Not to be treated as Royalty - AT....