2024 (3) TMI 1453

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.... PANDIT AND THE HON'BLE MR. JUSTICE C. M. POONACHA FOR THE APPELLANTS : SRI. Y. V. RAVIRAJ A/W SRI. M. DILIP, ADVOCATES FOR THE RESPONDENT : SRI. T. SURYANARAYANA, SENIOR COUNSEL FOR MS. TANMAYEE RAJKUMAR, ADVOCATE JUDGMENT 1. This appeal is by the Revenue challenging the order passed by the Income Tax Appellate Tribunal dated 29.08.2023 in Appeal IT(IT)A No.709/Bang/2022 partly allowing....

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....nnect services and transfer of capacity in foreign countries is chargeable to tax as royalty. It was argued by Shri. Pardiwala, that for subsequent years in assessee's own case, the ITAT has held that tax is not deductable when payment is made to non-resident telecom operator. This factual aspect is not refuted. Thus the Revenue has reviewed its earlier stand for the subsequent assessment year....