https://www.taxtmi.com/caselaws?id=462425 ITAT Delhi held that revenue from satellite transmission services for voice, data and programmes does not constitute "royalty" or "fee for technical services" under section 9(1)(vi) of IT Act and Article 12(4) of India-Netherlands DTAA. Following Delhi HC precedent in Asia Satellite case, the tribunal ruled that Finance Act 2012 amendments do not affect DTAA provisions, and income from data transmission services cannot be treated as royalty unless DTAAs are jointly amended by both countries. Decision favored assessee against revenue department's interpretation. en-us Fri, 07 Jun 2024 00:00:00 +0530 Sat, 21 Jun 2025 19:41:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=462425 ITAT Delhi held that revenue from satellite transmission services for voice, data and programmes does not constitute "royalty" or "fee for technical services" under section 9(1)(vi) of IT Act and Article 12(4) of India-Netherlands DTAA. Following Delhi HC precedent in Asia Satellite case, the tribunal ruled that Finance Act 2012 amendments do not affect DTAA provisions, and income from data transmission services cannot be treated as royalty unless DTAAs are jointly amended by both countries. Decision favored assessee against revenue department's interpretation. Case-Laws Income Tax Fri, 07 Jun 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=462425