2024 (3) TMI 1453

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....THE HON'BLE MR. JUSTICE S. G. 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 I....

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....hether the payments made to NTOS for providing interconnect 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 reviewe....