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An appeal is a continuation of assessment proceedings.

On the question whether  payments for interconnect services and bandwidth transfer in foreign countries is chargeable to tax as royalty the ITAT being the final fact finding authority is found to have taken a favourable stand for subsequent years in the Vodafone case of [2023] 457 ITR 189 (Kar).

For the straight reason that the Revenue/ITAT has reviewed its earlier stand for the subsequent assessment years the question was answered against the Revenue.

The Court also held the assessee entitled to benefits under the Double Taxation Avoidance Agreement while holding as untenable the order of ITAT that the DTAA cannot be considered in proceedings under section 201.

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