https://www.taxtmi.com/caselaws?id=406097 Receipts from satellite telecommunication services were held to be business income, not royalty, because the India-UK treaty contained an express definition of royalty that could not be enlarged by unilateral domestic amendments. The Tribunal also held that no permanent establishment existed in India through the liaison office or land earth station, as the Revenue failed to show business activity beyond liaison functions and the land earth station did not belong to the assessee. As no PE existed, ad hoc profit attribution under Rule 10 did not survive. Surcharge and cess were not sustained at the treaty rate, while TDS credit was remitted for factual verification. en-us Wed, 24 Mar 2021 00:00:00 +0530 Fri, 02 Apr 2021 12:45:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=406097 Receipts from satellite telecommunication services were held to be business income, not royalty, because the India-UK treaty contained an express definition of royalty that could not be enlarged by unilateral domestic amendments. The Tribunal also held that no permanent establishment existed in India through the liaison office or land earth station, as the Revenue failed to show business activity beyond liaison functions and the land earth station did not belong to the assessee. As no PE existed, ad hoc profit attribution under Rule 10 did not survive. Surcharge and cess were not sustained at the treaty rate, while TDS credit was remitted for factual verification. Case-Laws Income Tax Wed, 24 Mar 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=406097