Held that Payments for telecommunications services to associated enterprises is not Royalty or fees for technical services-Not liable to deduct tax at source. Followed order of earlier year which is affirmed by High Court. (AY.2017-18)
ACIT v. Verizon Communications India P. Ltd. (2024) 113 ITR 16 (SN) (Delhi)(Trib)
S. 40(a)(i) : Amounts not deductible-Deduction at source-Non-resident-Royalty-Fes for technical services-Payments for telecommunications services to associated enterprises is not Royalty or fees for technical services-Not liable to deduct tax at source-DTAA-India-USA [S. 9(1)(vi), 9(1)(vii), 195, Art. 12]
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