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Satellite Transponder Fees Not Taxable as Royalty Under DTAA Due to Treaty Protection
Case Law Details
- Case Name
- Asia Satellite Telecommunications Company Limited Vs ACIT (ITAT Delhi)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2020-21
- Courts
- All ITAT, ITAT Delhi
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Asia Satellite Telecommunications Company Limited Vs ACIT (ITAT Delhi)
Satellite Transponder Fees Not ‘Royalty’ Under DTAA: Delhi ITAT Applies New Skies & Engineering Analysis to India–Hong Kong Treaty
Delhi ITAT, Delhi Bench ‘D’, in Asia Satellite Telecommunications Company Ltd. Vs ACIT (International Taxation) (ITA Nos.2353 & 2674/Del/2023; AYs 2020-21 & 2021-22; order dated 19-12-2025), held that fees received for satellite transmission/transponder services from Indian customers are not taxable as ‘royalty’ in India under Article 12 of the India–Hong Kong DTA...
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