https://www.taxtmi.com/caselaws?id=785362 Payments for transponder services to a UK resident were not royalty under the India-UK DTAA because the payer obtained only satellite capacity, with no transfer of control, possession, or right to use the satellite or transponder. The treaty definition in Article 13 was confined to use of, or right to use, a secret process, and the domestic-law expansion in section 9(1)(vi) could not be imported into the treaty through Article 3(3). As the recipient had no permanent establishment in India, the receipt was not taxable in India and no withholding obligation under section 195 arose. en-us Wed, 14 Jan 2026 00:00:00 +0530 Thu, 22 Jan 2026 08:41:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=785362 Payments for transponder services to a UK resident were not royalty under the India-UK DTAA because the payer obtained only satellite capacity, with no transfer of control, possession, or right to use the satellite or transponder. The treaty definition in Article 13 was confined to use of, or right to use, a secret process, and the domestic-law expansion in section 9(1)(vi) could not be imported into the treaty through Article 3(3). As the recipient had no permanent establishment in India, the receipt was not taxable in India and no withholding obligation under section 195 arose. Case-Laws Income Tax Wed, 14 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=785362