Satellite Rights Transfer is a Sale, Not Royalty, Under Income Tax Act Section 9(1) Explanation II (5.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....Grant of satellite rights - the transfer in favour of the assessee is a sale and therefore, excluded from the definition of royalty under sec.9(1) explanation II (5) of the Act – thus, the Tribunal has erred in concluding that the payments made by the appellant are Royalty and not sale - HC....