https://www.taxtmi.com/caselaws?id=310300 Receipts for satellite telecommunication services were treated as not constituting royalty under the Income-tax Act or the India-UK tax treaty, because the treaty's express royalty definition was held to be exhaustive and domestic amendments could not be imported into it. The liaison office, being limited to liaison functions under RBI approval, and the land earth station, being owned and operated by the Indian customer, did not establish a permanent establishment in India. In the absence of a permanent establishment, the ad hoc attribution and profit estimation under Rule 10 could not survive, and the related additions were deleted. en-us Tue, 31 May 2022 00:00:00 +0530 Wed, 18 Oct 2023 05:30:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=310300 Receipts for satellite telecommunication services were treated as not constituting royalty under the Income-tax Act or the India-UK tax treaty, because the treaty's express royalty definition was held to be exhaustive and domestic amendments could not be imported into it. The liaison office, being limited to liaison functions under RBI approval, and the land earth station, being owned and operated by the Indian customer, did not establish a permanent establishment in India. In the absence of a permanent establishment, the ad hoc attribution and profit estimation under Rule 10 could not survive, and the related additions were deleted. Case-Laws Income Tax Tue, 31 May 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=310300