https://www.taxtmi.com/caselaws?id=246768 Transponder fees paid for satellite broadcasting services were analysed as royalty under the Income-tax Act and the India-USA DTAA because the treaty and domestic definition were treated as materially pari materia. As the treaty did not define "process," domestic law meaning applied under Article 3(2), and Explanation 6 to section 9(1)(vi) was read to include satellite transmission, including uplinking, amplification and downlinking. On that basis, use of transponder capacity was treated as consideration for use of a process, bringing the payment within royalty and supporting withholding under section 195. en-us Fri, 28 Mar 2014 00:00:00 +0530 Tue, 29 Jul 2025 14:11:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=246768 Transponder fees paid for satellite broadcasting services were analysed as royalty under the Income-tax Act and the India-USA DTAA because the treaty and domestic definition were treated as materially pari materia. As the treaty did not define "process," domestic law meaning applied under Article 3(2), and Explanation 6 to section 9(1)(vi) was read to include satellite transmission, including uplinking, amplification and downlinking. On that basis, use of transponder capacity was treated as consideration for use of a process, bringing the payment within royalty and supporting withholding under section 195. Case-Laws Income Tax Fri, 28 Mar 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=246768