In absence of DTAA No tax on payments received by non-resident for IUC from Indian company

Globe Teleservices Ltd. Vs DCIT (ITAT Bangalore)

In the realm of international taxation, the case of Globe Teleservices Ltd. vs. DCIT holds significant importance, particularly in clarifying the taxability of payments received by non-resident entities from Indian companies. The crux of the dispute revolved around whether Interconnect Usage Charges (IUC) received by Globe Teleservices Ltd., a Hong Kong-based company, from Vodafone South Ltd., an Indian entity, could be deemed as royalty under section 9(1)(vi) of the Income Tax Act.

The intricate legal battle commenced when th

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