https://www.taxtmi.com/caselaws?id=355550 Payments for transponder services to a non-resident were analysed under the service agreement and the applicable DTAA, and were treated as outside the treaty definition of royalty. The Tribunal applied its earlier orders and the payee-side reasoning, and held that a unilateral amendment in domestic tax law cannot enlarge or alter an express treaty definition of royalty. As the receipts were not taxable in India as royalty, no withholding obligation arose under section 195. The separate claim for interest on refund under section 244A was not decided on merits and was remitted to the Assessing Officer for fresh consideration in light of the earlier order and the applicable circular. en-us Fri, 09 Feb 2018 00:00:00 +0530 Wed, 28 Jan 2026 13:17:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=355550 Payments for transponder services to a non-resident were analysed under the service agreement and the applicable DTAA, and were treated as outside the treaty definition of royalty. The Tribunal applied its earlier orders and the payee-side reasoning, and held that a unilateral amendment in domestic tax law cannot enlarge or alter an express treaty definition of royalty. As the receipts were not taxable in India as royalty, no withholding obligation arose under section 195. The separate claim for interest on refund under section 244A was not decided on merits and was remitted to the Assessing Officer for fresh consideration in light of the earlier order and the applicable circular. Case-Laws Income Tax Fri, 09 Feb 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=355550