Receipt of IUC charges cannot be taxed as Royalty under Article 12 India- Japan DTAA,ruled ITAT
The Two member bench of Bangalore Income Tax Appellate Tribunal ( ITAT ) held that the receipt of Interconnect Utility Charges ( IUC ) charges cannot be taxed as Royalty under Article 12 India- Japan DTAA. The Assessee, KDDI Corporation,is engaged in the business of providing telecommunication services. The assessee provides fixed, mobile, wholesale and associated…
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