https://www.taxtmi.com/caselaws?id=417474 Transponder charges paid to non-resident satellite operators were treated as not constituting royalty under section 9(1)(vi) and the applicable DTAA, so tax was not required to be withheld under section 195. The analysis followed binding precedent that payments for satellite transponder facilities do not fall within royalty, and that a domestic-law amendment cannot expand an unamended treaty definition unless the treaty itself is revised. On that basis, the existing appellate relief in favour of the assessee was maintained and the Revenue's challenge failed. en-us Thu, 20 Jan 2022 00:00:00 +0530 Sat, 22 Jan 2022 09:55:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=417474 Transponder charges paid to non-resident satellite operators were treated as not constituting royalty under section 9(1)(vi) and the applicable DTAA, so tax was not required to be withheld under section 195. The analysis followed binding precedent that payments for satellite transponder facilities do not fall within royalty, and that a domestic-law amendment cannot expand an unamended treaty definition unless the treaty itself is revised. On that basis, the existing appellate relief in favour of the assessee was maintained and the Revenue's challenge failed. Case-Laws Income Tax Thu, 20 Jan 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=417474