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Sum paid by ‘JIO’ for availing bandwidth services not taxable as royalty as per India-Singapore tax treaty

September 13, 2019[2019] 108 325 (Mumbai)/[2019] 73 ITR(T) 194 (Mumbai)

INTERNATIONAL TAXATION : Where assessee-company had entered into a 'bandwith services' agreement with a Singaporean company which enabled it to establish, install, maintain, operate and provide telecommunication services in Singapore and also provide bandwith services to service recipients across globe as amount paid by assessee for availing standard bandwith services was neither towards use of industrial, commercial or scientific equipments nor towards secret process, it could not be characterised as 'royalty' as per India-Singapore DTAA
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