Tuesday, July 5, 2011

Payment made by Indian customers to Singapore Company for use of telecom ne

Payment made by Indian customers to Singapore Company for use of telecom network infrastructure is royalty for use of `process'

Income-tax : The payment made by the Indian customer to Singapore company for use of telecom network infrastructure is not royalty for the use of equipment, it is the royalty for the use of `process' [Section 90 of the Income-tax Act, 1961 read with Article 12(3) of the Indo-Singapore DTAA - Double Taxation Relief - Where agreement exists (Royalties and Fees for Technical Services)] - [2011] 10 taxmann.com 93 (Chennai - ITAT)

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