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of <h1>Karnataka High Court Rules Payments to Non-Resident Telecoms Not Royalties, Clarifies DTAA and TDS Applicability.</h1> The Karnataka High Court addressed the tax obligations of a telecommunications company concerning payments to non-resident telecom operators for international services. The court examined whether these payments should be classified as 'royalty' under Indian tax laws and the Double Taxation Avoidance Agreement (DTAA). The court ruled that such payments are not royalties and thus not subject to Tax Deducted at Source (TDS). It emphasized the applicability of DTAA provisions, limiting Indian tax authorities' jurisdiction over foreign-sourced income. The court also held that retrospective tax law amendments do not affect past compliant transactions. This judgment clarifies cross-border tax obligations and the interpretation of international tax treaties.
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