HC Remands Case to Assess Viacom 18’s Transponder Payments as ‘Royalty’ Under India-US DTAA

Advertisement Viacom 18 Media Pvt Ltd Vs DCIT (Bombay High Court) HC remanded back to verify if Viacom 18’s transponder payments qualified as ‘Royalty’ under India-US DTAA and Tax Law Conclusion: Since lower authorities had passed non-speaking orders without examining the technical nature of services rendered or the clauses of the transponder agreement, therefore, the Court directed to CIT(A) for a fresh factual determination on whether payments made by the company to Intelsat Corporation for transponder services qualify as “royalty” under Section 9(1)(vi) of the Income Tax Act, 1...