Receipt of IUC Charges by Telefonica from Indian customers /end users cannot be taxed as Royalty / FTS under Section 9(1)(vi)/(vii) of Income Tax Act and India-Spain DTAA: ITAT [Read Order]

By Fathima Karama A.M - On September 2, 2023 7:15 pm - 2 mins read
Receipt - IUC - Receipt of IUC Charges - IUC Charges - Telefonica - India-Spain DTAA - taxscan

The Bangalore Bench of Income Tax Appellate Tribunal) ITAT) has held that the receipt of interconnectivity utility charges (IUC) from Indian customers or end users could not be taxed as royalty or Fee for Technical Services (FTS) under Section 9(1)(vi)/(vii) of Income Tax Act, 1961 and also as per India-Spain Double Taxation Avoidance Agreement. The…

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