No addition on account of Royalty Income received by UK Telecom Company from Indian Telecom Company for rendering roaming services to customers abroad

Telefonica UK Limited Vs DCIT (ITAT Mumbai)

Conclusion: Income received by assessee-UK telecom company from an Indian telecom company for rendering roaming services to customers abroad was not ‘royalty’ as assessee-UK had not provided any right, as mentioned in Explanation 2 to Section 9(1)(vi), or any kind of use of any process or equipment to VIL

Held: Assessee-UK was a non-resident telecommunication service provider, primarily engaged in the busines

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