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Bandwidth Charges Not Taxable as Royalty Under India-Singapore DTAA: ITAT Delhi
Case Law Details
- Case Name
- Telstra Singapore Pte Ltd. Vs DCIT (ITAT Delhi)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2022-23
- Courts
- All ITAT, ITAT Delhi
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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/...
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