Payments Received Towards Interconnectivity Utility Charges From Indian Customers Is Not Royalty under Article 12 of DTAA: ITAT [Read Order]

While allowing the appeal of the assessee, the ITAT held that the receipt of IUC charges cannot be taxed as royalty under Article 12 of the India-Japan DTAA.
Payments Received - Interconnectivity Utility Charges From Indian Customers - Royalty - Article 12 of DTAA - ITAT - TAXSCAN

The Bangalore bench of the Income Tax Appellate Tribunal (ITAT) has held that payments received by the assessee towards interconnectivity utility charges from Indian customers or end users cannot be considered royalties to be brought to tax in India. The assessee/appellant M/s. KDDI Corporation is incorporated in Japan and is in the business of providing…

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