Voice Termination Charges Not Royalty Due to Absence of Secret Process Under DTAA

Reliance Jio Infocomm USA Inc. Vs DCIT (ITAT Mumbai) The appeal was filed against the final assessment order dated 30.06.2023 passed under sections 143(3) read with 144C(13) for Assessment Year 2020–21, pursuant to directions issued by the Dispute Resolution Panel (DRP) under section 144C(5). Facts of the Case The assessee, a wholly owned subsidiary of an Indian telecom company, is engaged in telecom-related services including technical support through its Advanced Technology Operation Centre (ATOC) in the USA, international long-distance services (including voice termination), and marketing...