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

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, 1961, and Article ...