assessee had not deducted tax at source from the DATA link
charges paid to various telecom service providers. As per the AO, the
assessee should ... have deducted tax at source from the said DATA link
charges under section 194J of the Act. The plea of the assessee before
DTAA. Certain reimbursements made by CIS in the nature of link charges,
software payments etc. were not offered for taxation since it claimed that
they ... Article 12 of the DTAA.
3.6. AO also held the IPLC/link charges are taxable as "Equipment
Royalty" in terms of clause
Reduction of Technical Fees and Satellite Link Charges
from Export Turnover (`.17,359,069 & `.20,210,502).
3. Disallowances under section ... monthly half circuit
charges/international half circuit charges and rent for
TMI - Frame Relay CCT charges including port charges.
The port charges, however, were calculated
software. (2) Data
connectivity charges (also known as Network connectivity charges, LAN
connectivity charges, Link connectivity charges, Link charges etc., (3) Data
Centre Racks ... regard to payments towards Data Connectivity Charges (also
known as Network Connectivity charges, Lan Connectivity charges,
Bandwidth Charges, Link Connectivity charges, Link Charges
link charges/IPLC charges as royalty:
16. The next issue raised by the Revenue is the taxability of payment of
link charges/IPLC charges ... taxability of
payment of link charges/IPLC charges as royalty. Accordingly, this issue;
taxability of payment of link charges/IPLC charges as royalty is decided
link charges/IPLC charges as royalty:
16. The next issue raised by the Revenue is the taxability of payment of
link charges/IPLC charges ... taxability of
payment of link charges/IPLC charges as royalty. Accordingly, this issue;
taxability of payment of link charges/IPLC charges as royalty is decided
link charges/IPLC charges as royalty:
16. The next issue raised by the Revenue is the taxability of payment of
link charges/IPLC charges ... taxability of
payment of link charges/IPLC charges as royalty. Accordingly, this issue;
taxability of payment of link charges/IPLC charges as royalty is decided
regard to payments towards Data Connectivity Charges (also
known as Network Connectivity charges, Lan Connectivity charges,
Bandwidth Charges, Link Connectivity charges, Link Charges ... regard to payments towards Data Connectivity Charges (also
known as Network Connectivity charges, Lan Connectivity charges,
Bandwidth Charges, Link Connectivity charges, Link Charges
regard to payments towards Data Connectivity Charges (also
known as Network Connectivity charges, Lan Connectivity charges,
Bandwidth Charges, Link Connectivity charges, Link Charges ... regard to payments towards Data Connectivity Charges (also
known as Network Connectivity charges, Lan Connectivity charges,
Bandwidth Charges, Link Connectivity charges, Link Charges
foreign currency
in respect of link charges, payment to employees, travelling, legal
& professional charges and power charges, both from the export
turnover and from ... exclude the link charges as well as the payment to
employees, legal & professional charges, travelling and power charges
ITA No.427 & 429/Bang
