https://www.taxtmi.com/caselaws?id=449302 ITAT Delhi held in favor of the assessee regarding income from satellite transmission services. The AO had classified revenue from voice, data and programme transmission services as royalty under Section 9(1)(vi) or alternatively as fees for technical services under Section 9(1)(vii) and India-Netherlands DTAA provisions. Following Delhi HC precedent, the tribunal ruled that domestic law amendments cannot unilaterally change treaty interpretations without joint amendment by both countries. The impugned addition was deleted and credit for taxes deducted at source was directed to be granted. en-us Tue, 06 Feb 2024 00:00:00 +0530 Thu, 08 Feb 2024 11:34:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=449302 ITAT Delhi held in favor of the assessee regarding income from satellite transmission services. The AO had classified revenue from voice, data and programme transmission services as royalty under Section 9(1)(vi) or alternatively as fees for technical services under Section 9(1)(vii) and India-Netherlands DTAA provisions. Following Delhi HC precedent, the tribunal ruled that domestic law amendments cannot unilaterally change treaty interpretations without joint amendment by both countries. The impugned addition was deleted and credit for taxes deducted at source was directed to be granted. Case-Laws Income Tax Tue, 06 Feb 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=449302