https://www.taxtmi.com/caselaws?id=349672 Receipts from transponder services were held not to constitute royalty under Article 12 of the India-Thailand DTAA because the customer did not obtain control or possession of the satellite equipment or any secret process. The domestic retrospective Explanations to section 9(1)(vi) could broaden taxability under the Income-tax Act, but they could not unilaterally alter an already existing treaty definition of royalty. The treaty text therefore continued to govern, and the receipts were not taxable in India on that basis. en-us Mon, 16 Oct 2017 00:00:00 +0530 Tue, 17 Oct 2017 18:42:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=349672 Receipts from transponder services were held not to constitute royalty under Article 12 of the India-Thailand DTAA because the customer did not obtain control or possession of the satellite equipment or any secret process. The domestic retrospective Explanations to section 9(1)(vi) could broaden taxability under the Income-tax Act, but they could not unilaterally alter an already existing treaty definition of royalty. The treaty text therefore continued to govern, and the receipts were not taxable in India on that basis. Case-Laws Income Tax Mon, 16 Oct 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=349672