Payment of IUC Charges is not “Fee for Technical Services” or “Royalty”

Bharat Sanchar Nigam Ltd Vs ACIT (ITAT Delhi) ITAT Delhi held that payment of IUC Charges is not “Fee for Technical Services” or “Royalty” within the meaning of its definition as per section 9(l)(vi) and 9(l)(vii) of the Act. Accordingly, disallowance u/s 40(a)(ia) on account of non-deduction of TDS unjustified. Facts- The appeal has been preferred by the Assessee against order of CIT(A) arising out of an appeal before it passed under section 143(3)/ 148 of the Income Tax Act. Assessee contested confirmation of disallowance u/s 40(a)(ia) of the Act alleging that relationshi...