Bandwidth Charges Not Taxable as Royalty Under India-Singapore DTAA: ITAT Delhi

Telstra Singapore Pte Ltd. Vs DCIT (ITAT Delhi) Bandwidth Is Not Royalty—Again & Again: Telstra Singapore Wins Yet Another Round at ITAT Delhi Assessee, a Singapore tax resident, received ₹8.90 crore from Indian customers for providing international telecom connectivity services such as IPLC & MPLS. AO, following earlier draft orders, treated bandwidth receipts as royalty u/s 9(1)(vi) & Article 12(3) of India–Singapore DTAA, alleging use of equipment, process & imparting of information, and passed final order u/s 143(3) r.w.s. 144C. Penalty proceedings u/s 270A were also ...