https://www.taxtmi.com/caselaws?id=189201 Receipts from satellite transmission services were treated as not taxable in India as royalty or otherwise under section 9(1)(vi), section 9(1)(vii) and Article 12 of the India-US treaty, because the relevant year involved identical facts already covered by the Tribunal's earlier order and the Delhi High Court ruling in Asia Satellite Telecommunications. Applying section 90(2), the Tribunal held that the assessee was entitled to the more beneficial treaty position. The revenue's reliance on the assessment order did not displace the binding effect of the earlier decision, and the departmental appeal was rejected. en-us Mon, 16 Jan 2012 00:00:00 +0530 Tue, 25 Apr 2023 11:49:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=189201 Receipts from satellite transmission services were treated as not taxable in India as royalty or otherwise under section 9(1)(vi), section 9(1)(vii) and Article 12 of the India-US treaty, because the relevant year involved identical facts already covered by the Tribunal's earlier order and the Delhi High Court ruling in Asia Satellite Telecommunications. Applying section 90(2), the Tribunal held that the assessee was entitled to the more beneficial treaty position. The revenue's reliance on the assessment order did not displace the binding effect of the earlier decision, and the departmental appeal was rejected. Case-Laws Income Tax Mon, 16 Jan 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=189201