ORDER

PER BEENA PILLAI, JUDICIAL MEMBER

Present appeals are filed by assessee against the separate orders passed by the Ld.CIT(International Taxation), Circle – 2(1), Bangalore for A.Ys. 2013-14 to 2015-16.

2. Brief facts of the case are as under:

2.1 It is submitted by the Ld.AR that assessee is incorporate in Japan and is engaged in the business of providing telecommunication services. The assessee provides fixed, mobile, wholesale and associated telecommunication services across the globe.

2.2 It is further submitted that the assessee is a tax resident of Japan in accordance with Article 4 of the Double Taxation Avoidance Agreement between India – Japan (“DTAA” or “tax treaty”) and it is entitled to beneficial provisions of the India – Japan DTAA. It is also submitted that the assessee does not have any presence in India either in form of an office, a branch or any other fixed place of business in India.

2.3 The Ld.AR submitted that for the years under consideration, the assessee provided telecom interconnect facility to various Indian telecom operators including Vodafone South Ltd. and has received payment on account of interconnect usage charges as under: