https://www.taxtmi.com/caselaws?id=785885 Payments for satellite transponder service charges to a UK resident were analysed under the Income-tax Act and the India-UK DTAA. The Tribunal relied on binding High Court authority that, for treaty purposes, "process" in the royalty article means a secret process, and that a unilateral domestic amendment enlarging the definition of royalty cannot override the treaty absent bilateral amendment. The transponder arrangement was characterised as a service arrangement for uplinking and downlinking television signals, not a grant of rights in a secret process. On that basis, the fees were not royalty under the DTAA and no tax deduction was required under section 195. en-us Fri, 30 Jan 2026 00:00:00 +0530 Mon, 02 Feb 2026 08:20:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=785885 Payments for satellite transponder service charges to a UK resident were analysed under the Income-tax Act and the India-UK DTAA. The Tribunal relied on binding High Court authority that, for treaty purposes, "process" in the royalty article means a secret process, and that a unilateral domestic amendment enlarging the definition of royalty cannot override the treaty absent bilateral amendment. The transponder arrangement was characterised as a service arrangement for uplinking and downlinking television signals, not a grant of rights in a secret process. On that basis, the fees were not royalty under the DTAA and no tax deduction was required under section 195. Case-Laws Income Tax Fri, 30 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=785885