https://www.taxtmi.com/highlights?id=99453 Explanations 4 to 6 to section 9(1)(vi) were held to expand the definition of royalty and to operate prospectively from 01.04.2012, following the Supreme Court ruling in Engineering Analysis and the assessee's earlier case. On that basis, remittance for IPLC and related bandwidth services to a non-resident was not taxable as royalty for the years in question, so no obligation to deduct tax at source under section 195 arose. Consequently, disallowance under section 40(a)(i) and consequential action under section 201, including interest liability, could not be sustained. The Court also noted that the law does not require an impossible act, and the questions of law were answered for the assessee. en-us Mon, 04 May 2026 08:42:21 +0530 Mon, 04 May 2026 08:42:21 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=99453 Explanations 4 to 6 to section 9(1)(vi) were held to expand the definition of royalty and to operate prospectively from 01.04.2012, following the Supreme Court ruling in Engineering Analysis and the assessee's earlier case. On that basis, remittance for IPLC and related bandwidth services to a non-resident was not taxable as royalty for the years in question, so no obligation to deduct tax at source under section 195 arose. Consequently, disallowance under section 40(a)(i) and consequential action under section 201, including interest liability, could not be sustained. The Court also noted that the law does not require an impossible act, and the questions of law were answered for the assessee. Highlights Income Tax Mon, 04 May 2026 08:42:21 +0530 https://www.taxtmi.com/highlights?id=99453