Amount for use of transponder of telecommunication service charges doesn’t qualify as royalty

Inmarsat Solutions BV Vs ACIT (ITAT Delhi) Held that the amounts received for the use of transponder of tele-communication service charges are not royalty under section 9(1)(vi) of the Income Tax Act and also under Article 12(8) of Indo Netherland DTAA. Facts- The Assessee is a company incorporated and registered under the laws of the Netherlands. The Assessee derives income from transmission of satellite signals from ship to the customers and vice versa. An equipment is located on a ship which captures the satellite signals. During the year, the Assessee has earned receipt from various custom...