https://www.taxtmi.com/caselaws?id=400214 Satellite telecommunication receipts paid to a UK resident were held not taxable as royalty under the Act or the India-UK treaty, because the treaty definition could not be enlarged by domestic-law amendments and the prior rulings on similar transponder services were followed. No permanent establishment in India was found through the liaison office or land earth station, as the liaison office remained limited to approved liaison activity and the land earth station was not shown to be a fixed place at the assessee's disposal. Surcharge and education cess were also held unsustainable over and above the treaty tax rate, requiring recomputation at the treaty rate. en-us Fri, 23 Oct 2020 00:00:00 +0530 Fri, 30 Oct 2020 23:58:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=400214 Satellite telecommunication receipts paid to a UK resident were held not taxable as royalty under the Act or the India-UK treaty, because the treaty definition could not be enlarged by domestic-law amendments and the prior rulings on similar transponder services were followed. No permanent establishment in India was found through the liaison office or land earth station, as the liaison office remained limited to approved liaison activity and the land earth station was not shown to be a fixed place at the assessee's disposal. Surcharge and education cess were also held unsustainable over and above the treaty tax rate, requiring recomputation at the treaty rate. Case-Laws Income Tax Fri, 23 Oct 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=400214