Payment towards interconnect usage charges to foreign telecom operators not taxable in India: ITAT Mumbai

Dialog Axiata PLC Vs DCIT (ITAT Mumbai) ITAT Mumbai held that the payment made towards interconnect usage charges to foreign telecom operators does not accrue or arise in India and in the absence of any permanent establishment in India could not be brought to tax in India under Article 7 of DTAA. Facts- The assessee company is a non resident telecommunication operator rendering international carriage and connectivity services to telecom operators of other countries to facilitate seamless connectivity and carriage of telecommunication traffic in Sri Lanka. The assessee’s case was reopened by ...