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    <title>2015 (5) TMI 1272 - ITAT DELHI</title>
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    <description>Taxability of payments to a non-resident satellite company for downlinking and international footprints was examined in light of the amended scope of fee for included services and retrospective explanations. The tribunal directed re-evaluation of whether such payments qualify as royalty or fee for included services or instead constitute business profits under the applicable double taxation agreement with the United States, with the assessing officer to decide afresh after hearing the taxpayer on treaty entitlement; the appeal was allowed for statistical purposes and the matter remitted for fresh adjudication.</description>
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