Satellite Transponder Fees Not Taxable as Royalty Under DTAA Due to Treaty Protection

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...