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    <title>2015 (2) TMI 1282 - ITAT MUMBAI</title>
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    <description>Transponder fee payments to a foreign satellite operator were treated as royalty because the amounts were paid for the use of, or right to use, a process under both the Income-tax Act and the India-USA Tax Treaty. The Tribunal followed its earlier co-ordinate bench ruling in the assessee&#039;s own case and found no distinguishing facts or contrary authority to depart from that view. On that basis, the payments were held taxable as royalty and subject to withholding under section 195.</description>
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