https://www.taxtmi.com/caselaws?id=776786 Receipts for the use or right to use satellite transponders for telecommunication services were treated as not constituting royalty, following settled authority that such consideration falls outside that characterisation. The court also held that the Finance Act, 2012 amendment to the Income-tax Act could not expand the meaning of royalty under Article 13 of the India-UK DTAA, because the treaty definition continued to govern the tax treatment of the receipts. The Revenue's challenge therefore failed, and the receipts remained outside royalty taxation under the applicable treaty framework. en-us Tue, 12 Aug 2025 00:00:00 +0530 Tue, 19 Aug 2025 08:38:27 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=776786 Receipts for the use or right to use satellite transponders for telecommunication services were treated as not constituting royalty, following settled authority that such consideration falls outside that characterisation. The court also held that the Finance Act, 2012 amendment to the Income-tax Act could not expand the meaning of royalty under Article 13 of the India-UK DTAA, because the treaty definition continued to govern the tax treatment of the receipts. The Revenue's challenge therefore failed, and the receipts remained outside royalty taxation under the applicable treaty framework. Case-Laws Income Tax Tue, 12 Aug 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=776786