Payments towards Interconnectivity Utility Charges not royalty/ FTS hence not taxable

Telefonica Depreciation Espana SA Vs ACIT(IT) (ITAT Bangalore) ITAT Bangalore held that payments received by assessee towards interconnectivity utility charges from Indian customers / end users cannot be considered as Royalty / FTS to be brought to tax in India under section 9(1)(vi)/(vii) of the Act and also as per DTAA. Facts- The assessee is engaged in the business of providing telecommunications services, interconnection services, internet services, etc. The assessee entered into interconnect services agreements that enables subscribers of one telecom operator to call a subscriber of anoth...