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ThynkTax /Tax Reference /Case Laws /Bharti Cellular - interconnect

Bharti Cellular - interconnect

High Court·2014·ITR
Facts

Interconnect charges paid by Bharti Cellular to other telecom operators.

Issue

Whether such payments constitute "fees for technical services" under Section 194J?

Held

No. Interconnect involves use of equipment by the recipient, but no human intervention - hence not "technical services".

Ratio

FTS requires human intervention; standard automated service fees are not FTS.

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