https://www.taxtmi.com/caselaws?id=310328 Receipts from satellite telecommunication services were treated as not constituting royalty under the Act or the India-UK tax treaty, because the Tribunal followed its earlier orders and held that unilateral amendments to the domestic royalty definition cannot expand treaty taxability. The Liaison Office was not regarded as a permanent establishment since its activities remained within RBI-approved liaison functions, and the Land Earth Station, being owned and operated by Tata Communications Limited, could not be attributed to the assessee as its fixed place of business. The TDS credit shortfall was not decided on merits and was remitted to the Assessing Officer for verification of the claim and records. en-us Mon, 22 Aug 2022 00:00:00 +0530 Wed, 18 Oct 2023 20:45:31 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=310328 Receipts from satellite telecommunication services were treated as not constituting royalty under the Act or the India-UK tax treaty, because the Tribunal followed its earlier orders and held that unilateral amendments to the domestic royalty definition cannot expand treaty taxability. The Liaison Office was not regarded as a permanent establishment since its activities remained within RBI-approved liaison functions, and the Land Earth Station, being owned and operated by Tata Communications Limited, could not be attributed to the assessee as its fixed place of business. The TDS credit shortfall was not decided on merits and was remitted to the Assessing Officer for verification of the claim and records. Case-Laws Income Tax Mon, 22 Aug 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=310328