Telstra Singapore Pte. Ltd. v. DCIT (2024) 207 ITD 73 (Delhi) (Trib.)

S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Business of providing digital transmission of data-Bandwidth charges received from Indian customers-Not taxable as royalty-DTAA-India-Singapore. [Art. 12(3)]

Assessee, a non-resident corporate entity, which is  engaged in business of providing digital transmission of data through International Private Leased Circuits or Multiprotocol Label Switching to facilitate high speed data connectivity, Bandwidth charges received from Indian Customers were not taxable as royalty income either under section 9(1)(vi) or under Article 12(3). (AY. 2021-22)

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