https://www.taxtmi.com/caselaws?id=62754 The court determined that the services rendered by the assessees through their satellites for telecommunication and broadcasting constitute a 'process', not a 'secret process'. It concluded that the term 'secret' does not qualify 'process' in Explanation 2 to section 9(1)(vi) of the Income-tax Act or the relevant Treaties. The payments received by the assessees for the use of their satellites were deemed 'royalty' under section 9(1)(vi) of the Income-tax Act, 1961, and are liable to tax according to the domestic law and relevant DTAA provisions. en-us Fri, 16 Oct 2009 00:00:00 +0530 Tue, 26 Dec 2023 10:20:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=62754 The court determined that the services rendered by the assessees through their satellites for telecommunication and broadcasting constitute a 'process', not a 'secret process'. It concluded that the term 'secret' does not qualify 'process' in Explanation 2 to section 9(1)(vi) of the Income-tax Act or the relevant Treaties. The payments received by the assessees for the use of their satellites were deemed 'royalty' under section 9(1)(vi) of the Income-tax Act, 1961, and are liable to tax according to the domestic law and relevant DTAA provisions. Case-Laws Income Tax Fri, 16 Oct 2009 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=62754