https://www.taxtmi.com/caselaws?id=772449 Transponder service payments to a non-resident were treated as not constituting royalty under section 9(1)(vi) and Article 13 of the India-UK DTAA because the treaty's own royalty definition controlled, and later domestic amendments could not enlarge it. The arrangement did not confer a right to use a process or equipment in the treaty sense, so the payments were not taxable as royalty. As a result, the payer had no obligation to deduct tax at source under section 195, and the Revenue's challenge failed. en-us Tue, 27 May 2025 00:00:00 +0530 Mon, 09 Jun 2025 07:29:44 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=772449 Transponder service payments to a non-resident were treated as not constituting royalty under section 9(1)(vi) and Article 13 of the India-UK DTAA because the treaty's own royalty definition controlled, and later domestic amendments could not enlarge it. The arrangement did not confer a right to use a process or equipment in the treaty sense, so the payments were not taxable as royalty. As a result, the payer had no obligation to deduct tax at source under section 195, and the Revenue's challenge failed. Case-Laws Income Tax Tue, 27 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=772449