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    <title>2017 (8) TMI 1429 - ITAT MUMBAI</title>
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    <description>Transponder fees paid to a non-resident satellite operator were treated as royalty under the expanded meaning of &quot;process&quot; in section 9(1)(vi) of the Income-tax Act, and were therefore taxable in India. The Tribunal applied judicial consistency, noting that the identical issue had already been decided against the assessee in earlier years and that no binding jurisdictional High Court ruling had overruled that view. On that basis, the withholding obligation under section 195 was upheld, and tax deduction at source on the transponder payments remained applicable.</description>
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      <title>2017 (8) TMI 1429 - ITAT MUMBAI</title>
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      <description>Transponder fees paid to a non-resident satellite operator were treated as royalty under the expanded meaning of &quot;process&quot; in section 9(1)(vi) of the Income-tax Act, and were therefore taxable in India. The Tribunal applied judicial consistency, noting that the identical issue had already been decided against the assessee in earlier years and that no binding jurisdictional High Court ruling had overruled that view. On that basis, the withholding obligation under section 195 was upheld, and tax deduction at source on the transponder payments remained applicable.</description>
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