Appellant fails to challenge ITAT ruling on Data Transmission Services not constituting royalty under Indo-Netherlands tax treaty

The Delhi HC dismissed the appellant's challenge to ITAT's ruling that Data Transmission Services do not constitute 'royalty' under Article 12 of the Indo-Netherlands Double Taxation Avoidance Agreement. The Court relied on its prior decision in Director of Income Tax vs. New Skies Satellite BV, holding that no question of law arises. The appeal and pending application were dismissed.

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The Delhi High Court, in an order by Justices S. Ravindra Bhat and A. K. Chawla, dismissed the appellant's challenge to the ITAT's ruling that Data Transmission Services do not constitute 'royalty' under Article 12 of the Indo-Netherlands Double Taxation Avoidance Agreement. The Court relied on its prior decision in *Director of Income Tax vs. New Skies Satellite BV*, (2016) 382 ITR 114, holding that "no question of law therefore arises." Consequently, the appeal and pending application were dismissed.

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