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of ITAT held that payments for transponder charges to Intelsat Global Sales and Marketing Limited do not constitute royalty under Section 9(1)(vi) of the Income Tax Act or the relevant Double Taxation Avoidance Agreement. Following precedents from Delhi HC and coordinate benches, the tribunal determined that the assessee is not liable to deduct tax at source under Section 195. No contrary evidence or judicial orders were presented to challenge prior rulings. The revenue department's appeal was consequently dismissed, affirming the earlier CIT(A) decision and maintaining the existing jurisprudential interpretation regarding such technical service payments.
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