Interconnect Charges Not Taxable as Royalty: ITAT Bangalore

DCIT (IT) Vs A1 Telekom Austria Aktiengesellschaft (ITAT Bangalore) Income Tax Appellate Tribunal (ITAT) Bangalore dismissed an appeal filed by the Deputy Commissioner of Income Tax (DCIT) against A1 Telekom Austria. The dispute centered around whether interconnect charges received by the non-resident telecom operator from Vodafone South Ltd. should be taxed as royalty in India under the Income Tax Act and the Double Taxation Avoidance Agreement (DTAA) between India and Austria. The Assessing Officer (AO) had classified these payments as royalty and issued a reassessment order, bringing them u...