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 e

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