DCIT v. Hinduja Global Solutions Ltd. (2025) 213 ITD 453 (Mum) (Trib.)

S. 40(a)(i): Amounts not deductible-Deduction at source-Non-resident –Royalty-Payments made towards internet, broadband and bandwidth charges to foreign parties did not constitute royalty-Not liable to deduct tax at source.[S.9(1)(vi), 195]

Held that payments made towards internet, broadband and bandwidth charges to foreign parties did not constitute royalty, hence not liable to deduct tax at source. Order of CIT A) was affirmed.  (AY. 2020-21)

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