https://www.taxtmi.com/caselaws?id=31306 Payment for access to satellite transponder capacity was treated as consideration for a transmission facility, not as payment for use of, or right to use, industrial, commercial or scientific equipment. On that basis, the receipt was not royalty under the treaty or the Income-tax Act, and it also did not constitute fees for technical services because no technical knowledge or know-how was made available. The foreign enterprise was found to have no permanent establishment in India for the contract, so the income was not taxable as business profits in India and section 195 withholding did not arise. en-us Wed, 22 Oct 2008 00:00:00 +0530 Sat, 06 Sep 2025 10:32:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=31306 Payment for access to satellite transponder capacity was treated as consideration for a transmission facility, not as payment for use of, or right to use, industrial, commercial or scientific equipment. On that basis, the receipt was not royalty under the treaty or the Income-tax Act, and it also did not constitute fees for technical services because no technical knowledge or know-how was made available. The foreign enterprise was found to have no permanent establishment in India for the contract, so the income was not taxable as business profits in India and section 195 withholding did not arise. Case-Laws Income Tax Wed, 22 Oct 2008 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=31306