2024 (9) TMI 1675

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..... 2024 (T-IT) - - - Income Tax - Accrual of income in India or not? - royalty income - interconnect service charges - HELD THAT:- As decided in M/S. VODAFONE IDEA LIMITED [ 2023 ( 7) TMI 1164 - KARNATAKA HIGH COURT ] held that tax is not deductable when payment is made to non-resident telecom operator. This factual aspect is not refuted. No infirmity in the orders under challenge. - The Hon'b .....

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..... fer of capacity in foreign countries is chargeable to tax as royalty. It was argued by Shri. Pardiwala, that for subsequent years in assessee s own case, the ITAT has held that tax is not deductable when payment is made to non-resident telecom operator. This factual aspect is not refuted. Thus the Revenue has reviewed its earlier stand for the subsequent assessment years placing reliance on Viacom .....

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