https://www.taxtmi.com/caselaws?id=433790 Receipts from Satellite Transmission Services were examined for taxability in India as royalty under Explanation II to section 9(1)(vi) of the Income-tax Act and Article 12(3) of the India-USA DTAA. The Tribunal followed its earlier decisions in the assessee's own case, which had been affirmed by the jurisdictional High Court, and found no distinguishing facts for the year under appeal. On that binding and consistent footing, the receipts were held not to constitute royalty, the royalty addition was deleted, and the assessment was set aside to that extent in favour of the assessee. en-us Tue, 31 Jan 2023 00:00:00 +0530 Wed, 08 Feb 2023 18:28:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=433790 Receipts from Satellite Transmission Services were examined for taxability in India as royalty under Explanation II to section 9(1)(vi) of the Income-tax Act and Article 12(3) of the India-USA DTAA. The Tribunal followed its earlier decisions in the assessee's own case, which had been affirmed by the jurisdictional High Court, and found no distinguishing facts for the year under appeal. On that binding and consistent footing, the receipts were held not to constitute royalty, the royalty addition was deleted, and the assessment was set aside to that extent in favour of the assessee. Case-Laws Income Tax Tue, 31 Jan 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=433790