High Court, following Engineering Analysis Centre of Excellence Pvt. Ltd. v. CIT(2021) 432 ITR 471 (SC)  allowed the assessee’s appeals, holding that the Double Taxation Avoidance Agreement could be considered in proceedings under section 201, that amendment to the provisions of section 9(1)(vi) inserting the Explanations would not result in amendment of the Double Taxation Avoidance Agreements, that the Department had no jurisdiction to bring to tax income that arose from extra-territorial sources, that the payments made to the non-resident telecommunications operators for providing inter-connectivity services and transfer of capacity in foreign countries was not chargeable to tax as royalty under section 9(1)(vi) and that therefore, the assessee is  not liable to deduct tax at source under section 195 thereon. Followed, CIT v. GE India Technology Centre Pvt Ltd (2024) 469 ITR 389 (SC).  SLP of Revenue is dismissed.  (AY.2008-09 to 2012-13, 2013-14 to 2015-16)