https://www.taxtmi.com/caselaws?id=466021 Satellite transmission receipts from offshore transponder services were analysed under the Act and the India-UK DTAA and were treated as outside equipment royalty, process royalty and fees for technical services because the provider did not own or operate equipment in India, had no role in the customers' Indian earth-station activities, and did not make technical knowledge available. The commentary also notes that the Indian affiliate performed only marketing functions, without authority to conclude contracts or manage the service, so no business connection or permanent establishment in India was established and the force of attraction rule did not apply. For a non-resident, interest under section 234B was also held unsustainable where tax deduction obligations rested on the payer. en-us Mon, 16 Oct 2023 00:00:00 +0530 Tue, 20 Jan 2026 21:18:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=466021 Satellite transmission receipts from offshore transponder services were analysed under the Act and the India-UK DTAA and were treated as outside equipment royalty, process royalty and fees for technical services because the provider did not own or operate equipment in India, had no role in the customers' Indian earth-station activities, and did not make technical knowledge available. The commentary also notes that the Indian affiliate performed only marketing functions, without authority to conclude contracts or manage the service, so no business connection or permanent establishment in India was established and the force of attraction rule did not apply. For a non-resident, interest under section 234B was also held unsustainable where tax deduction obligations rested on the payer. Case-Laws Income Tax Mon, 16 Oct 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=466021