https://www.taxtmi.com/caselaws?id=306191 Satellite transponder and bandwidth capacity receipts were held not to constitute royalty in India under section 9(1)(vi) of the Income-tax Act or Article 12 of the India-USA DTAA, because the retrospective amendment to section 9(1)(vi) could not be read to expand the treaty definition. The Tribunal followed its earlier order in the same matter and the jurisdictional High Court's binding view, including later authority on the same line. Consequential interest under section 234B did not survive independently once the taxability issue failed. en-us Thu, 20 Jun 2019 00:00:00 +0530 Mon, 16 Jan 2023 20:28:26 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=306191 Satellite transponder and bandwidth capacity receipts were held not to constitute royalty in India under section 9(1)(vi) of the Income-tax Act or Article 12 of the India-USA DTAA, because the retrospective amendment to section 9(1)(vi) could not be read to expand the treaty definition. The Tribunal followed its earlier order in the same matter and the jurisdictional High Court's binding view, including later authority on the same line. Consequential interest under section 234B did not survive independently once the taxability issue failed. Case-Laws Income Tax Thu, 20 Jun 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=306191