Faceless reassessment jurisdiction turned on retrospective AO definition, with later faceless-assessment changes treated as clarificatory and procedur...
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Satellite transponder service payments are discussed as consideration for standard communication services rather than royalty where the customer obtains no right to use, possess, operate or control the satellite, transponder or underlying process. The note states that a retrospective domestic-law expansion of royalty cannot unilaterally broaden the more beneficial India-USA treaty definition, which requires autonomous interpretation under international treaty principles. It further explains that withholding applies only to remittances chargeable to tax in the recipient's hands; consequently, payments not taxable as royalty under the treaty do not trigger a withholding obligation.
Satellite transponder service payments are discussed as consideration for standard communication services rather than royalty where the customer obtains no right to use, possess, operate or control the satellite, transponder or underlying process. The note states that a retrospective domestic-law expansion of royalty cannot unilaterally broaden the more beneficial India-USA treaty definition, which requires autonomous interpretation under international treaty principles. It further explains that withholding applies only to remittances chargeable to tax in the recipient's hands; consequently, payments not taxable as royalty under the treaty do not trigger a withholding obligation.
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