Assessee was engaged in business of marketing advertisement time of different television channels and paid transponder service fees to three companies based in USA, UK and Malaysia.AO  held that payments made for transponder service fee constituted royalty as same was a ‘process’ defined in Explanation 6 of section 9(1)(vi) and would be taxable in India. On appeal the Tribunal held that  term used in DTAA was ‘secret formula or process’, term ‘process’ as defined in Explanation 6 to section 9(1)(vi) could not be incorporated into DTAA as same would make meaning of secret redundant, thus payment made to foreign companies for utilization of transponder centered on a satellite would not be in nature of royalty in terms of relevant three DTAAs.  (AY. 2017-18 to 2020-21)