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of <h1>Delhi High Court Rules Payments for Telecom Services Aren't Royalties Under DTAA; Domestic Amendments Don't Alter Treaties.</h1> The article analyzes a Delhi High Court judgment on the taxation of royalties under Double Taxation Avoidance Agreements (DTAAs). The case focuses on whether payments for telecommunication services or satellite transponder capacity are considered royalties and thus taxable. The appellants argued that amendments to the Income Tax Act, 1961, should influence DTAA interpretations, while the respondents contended that DTAAs should be interpreted independently based on international law, OECD commentary, and precedents. The court concluded that domestic law amendments cannot alter treaty interpretations, and such payments do not qualify as royalties under DTAAs, emphasizing reliance on international principles and precedents.
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