Payment for Utilization of Transponder Centered on A Satellite is not Royalty

ACIT Vs Viacom 18 Media Pvt. ltd. (ITAT Mumbai)

The assessee has made payment for transponder service fees to three entities namely (1) intelsat Corporation, USA, (2) Intelsat global sales and marketing, UK and (3) MEAST satellite system, Malaysia. Assessee applied for an order u/s 195 (2) for Nil withholding tax certificates for payment of transponder services fees payable to the service providers.

The learned assessing officer rejected it holding that these payments are chargeable to tax

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