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 business of providing mobile and broadband services along with various other ancillary services in the United Kingdom. The arrangement of VIL with ...