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    <title>2025 (11) TMI 1832 - ITAT DELHI</title>
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    <description>ITAT Delhi held that income earned by the assessee from transmitting satellite signals from ship to customers and vice versa, through use of transponders, is not taxable in India as royalty. Relying on its earlier decision for AY 2021-22, the Tribunal held that such receipts are not &quot;royalty&quot; under s. 9(1)(vi) of the Income-tax Act and also do not qualify as royalty under Article 12(8) of the Indo-Netherlands DTAA. Consequently, the additions made as royalty income were deleted and the assessee&#039;s appeal was allowed.</description>
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      <title>2025 (11) TMI 1832 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=782364</link>
      <description>ITAT Delhi held that income earned by the assessee from transmitting satellite signals from ship to customers and vice versa, through use of transponders, is not taxable in India as royalty. Relying on its earlier decision for AY 2021-22, the Tribunal held that such receipts are not &quot;royalty&quot; under s. 9(1)(vi) of the Income-tax Act and also do not qualify as royalty under Article 12(8) of the Indo-Netherlands DTAA. Consequently, the additions made as royalty income were deleted and the assessee&#039;s appeal was allowed.</description>
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      <pubDate>Tue, 30 Sep 2025 00:00:00 +0530</pubDate>
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