Assessee, a UK based company, was engaged in business of providing telecommunication services and leasing of space segment capacity of navigational transponder.  It had entered into an agreement with Tata Communications Ltd. for providing satellite telecommunication services.  The Assessing Officer assessed the total receipt as royalty subjected to tax @ 10%. DRP up held the order of the Assessing Officer. On appeal The Tribunal held that amount received by assessee from providing Satellite Telecommunication services to Tata Communications Ltd   was not to be treated as royalty.  Assessing Officer held that assessee had a PE in India on two grounds, that Liaison Office (LO) of assessee constituted its PE in India; and that Land Earth Stations (LES) also constituted PE of assessee in India.  DRP up held the order of the Assessing Officer. On appeal The Tribunal held that activities on behalf of assessee and there were no income generating activities carried out by Liaison  Office  in India on facts, Liaisons  office   could not be treated as PE of assessee.    (AY. 2015-16)