https://www.taxtmi.com/caselaws?id=378982 Receipts from leasing transponders or bandwidth for satellite transmission services were held not taxable in India as royalty under section 9(1)(vi) and Article 12 of the India-USA DTAA. The tribunal followed earlier decisions in the assessee's own case and the jurisdictional High Court, holding that satellite transmission receipts did not constitute royalty on the binding treaty interpretation. It further held that the retrospective amendment to section 9(1)(vi) could not be used to enlarge the scope of taxation under the DTAA, and with no change in the material facts, the consistent earlier view was applied in favour of the assessee. en-us Tue, 26 Mar 2019 00:00:00 +0530 Wed, 24 Apr 2019 17:29:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=378982 Receipts from leasing transponders or bandwidth for satellite transmission services were held not taxable in India as royalty under section 9(1)(vi) and Article 12 of the India-USA DTAA. The tribunal followed earlier decisions in the assessee's own case and the jurisdictional High Court, holding that satellite transmission receipts did not constitute royalty on the binding treaty interpretation. It further held that the retrospective amendment to section 9(1)(vi) could not be used to enlarge the scope of taxation under the DTAA, and with no change in the material facts, the consistent earlier view was applied in favour of the assessee. Case-Laws Income Tax Tue, 26 Mar 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=378982