Court Rules Transponder Space Payments Not Royalties u/s 9(1)(vi); No Tax Deduction Needed u/s 195.

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....TDS u/s 195 - payment for use of 'transponder space' as Royalty u/s 9(1)(vi) - India US DTAA - when this income is not chargeable to tax in the hands of the recipient, no liability is there on the assessee to deduct tax at source.....