Income from bandwidth services provided outside India cannot be taxed as ‘Royalty’ under India-Singapore DTAA

Telstra Singapore Pte. Ltd. Vs DCIT (ITAT Delhi)

Conclusion: Income received on providing bandwidth services outside India was not taxable as ‘Royalty’ under India-Singapore Double Taxation Avoidance Agreement (DTAA) as mere receipt of service using equipment under the control, possession and operation of service provider would only be considered as transaction of a service and not to ‘use or right to use’ an equipment, and would not attract ‘Royalty’ under the Act or the Tax Treaty. Also

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