https://www.taxtmi.com/caselaws?id=466050 Payments for transponder access to a United States resident satellite operator with no permanent establishment in India were treated as not constituting royalty under Article 12 of the India-USA DTAA because the payer obtained only specified capacity and no control over the satellite or equipment. The wider domestic definition of royalty in Explanation 6 to section 9(1)(vi) was held not to expand the treaty meaning. As the amount was not chargeable to tax in India in the recipient's hands, no deduction of tax at source arose under section 195. en-us Thu, 25 Jan 2018 00:00:00 +0530 Tue, 20 Jan 2026 17:48:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=466050 Payments for transponder access to a United States resident satellite operator with no permanent establishment in India were treated as not constituting royalty under Article 12 of the India-USA DTAA because the payer obtained only specified capacity and no control over the satellite or equipment. The wider domestic definition of royalty in Explanation 6 to section 9(1)(vi) was held not to expand the treaty meaning. As the amount was not chargeable to tax in India in the recipient's hands, no deduction of tax at source arose under section 195. Case-Laws Income Tax Thu, 25 Jan 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=466050