S. 40(a)(i) : Amounts not deductible-Deduction at source-Non-resident-Royalty-Fes for technical services-Transponder fee and uplinking charges-Payment was not made for right to use any industrial, commercial or scientific equipment-Payment would not fall within ambit of royalty-Not liable to deduct tax at source-DTAA-India-USA [S.9(1)(vi), 9(1)(vii), Art. 12]