Courier transshipment of imported goods via named carrier to air cargo stations renewed until 30.01.2026; exemption conditional, strict controls apply...
Insurer's investment gains and investment write-downs face Section 263 revision; enquiry upheld, Rule 5(b)(ii) lapse sustained, late corrigendum quash...
Whether transponder service fees constitute 'royalty' under Article 13 of the India-UK DTAA and attract withholding under domestic TDS law. Relying on binding High Court precedents, the treaty term 'process' must be read as 'secret process' and unilateral domestic statutory amendments cannot be imported into the DTAA; therefore payments for satellite transponder services are characterisable as consideration for services, not royalty. Consequence: no withholding obligation arose on the payer under the domestic TDS regime in respect of those transponder service fees.
Whether transponder service fees constitute 'royalty' under Article 13 of the India-UK DTAA and attract withholding under domestic TDS law. Relying on binding High Court precedents, the treaty term 'process' must be read as 'secret process' and unilateral domestic statutory amendments cannot be imported into the DTAA; therefore payments for satellite transponder services are characterisable as consideration for services, not royalty. Consequence: no withholding obligation arose on the payer under the domestic TDS regime in respect of those transponder service fees.
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