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2013 (10) TMI 215 - BOMBAY HIGH COURT
TDS u/s 195 - whether reimbursement of lease line charges does/does not qualify as Royalty under Article 12 of India UK Treaty – Amount attributable to PE in India or not – Held that:- Amount received by the Respondent-Assessee as reimbursement of lease line charges and would not classify either as royalty or as income attributed to a Permanent Establishment in India - Reimbursement of lease line charges received by the Respondent-Assessee is the actual amount which is incurred by it on making payment to the international telecom operator - There is no income earned by Respondent-Assessee which is subject to tax but is only a reimbursement of lease line charges paid by it to international telecom operator – Decided against the Revenue.