Held that business of transmitting telecommunication signals to/from its customers, income earned was not in nature of royalties within ambit of Explanation 2 to section 9(1)(vi) and article 12(3) of India-USA and it was not liable to tax in India. (AY. 2015-16)
Intelsat Corporation v. ACIT (2022) 193 ITD 259 (Delhi)(Trib.)
S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty Business of transmitting telecommunication signals to/from its customers-Income earned was not in nature of royalties-Not liable to tax in India-DTAA-India-USA. [Art. 12(3)]