Telecom Interconnectivity Payments Ruled Taxable as "Royalty" and Technical Fees Under Indian Law.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....Income taxable in India - Taxability of the receipts as “Royalty" - telecom services comprising of interconnectivity services - Once the situs is outside India, then in order to determine whether the payments made by a resident of India to a non resident involves element of income is to be examined u/s 9 and in the present case, the Assessing Officer has examined the applicability of section 9(1) (vi) & 9(1)(vii) i.e. the payments involve royalty as well as fee for technical services. - Revenue appeal dismissed - AT....