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    <title>2018 (7) TMI 1165 - ITAT MUMBAI</title>
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    <description>Transponder lease payments made to a Malaysian satellite operator were treated as royalty under the Income-tax Act and the India-Malaysia DTAA, following the Tribunal&#039;s earlier orders in the assessee&#039;s own case and the post-amendment scope of section 9(1)(vi). The Tribunal did not depart from its consistent prior view, noting the absence of any binding jurisdictional High Court ruling to the contrary. On that basis, the payments were held taxable in India and the payer was required to deduct tax at source under section 195 because taxability had already been concluded against the assessee.</description>
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      <link>https://www.taxtmi.com/caselaws?id=363857</link>
      <description>Transponder lease payments made to a Malaysian satellite operator were treated as royalty under the Income-tax Act and the India-Malaysia DTAA, following the Tribunal&#039;s earlier orders in the assessee&#039;s own case and the post-amendment scope of section 9(1)(vi). The Tribunal did not depart from its consistent prior view, noting the absence of any binding jurisdictional High Court ruling to the contrary. On that basis, the payments were held taxable in India and the payer was required to deduct tax at source under section 195 because taxability had already been concluded against the assessee.</description>
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