High Court of Judicature at Bombay Considers Income Tax Appeals on Withholding Tax Obligation for Transponder Services Payments Under India-USA Double Taxation Avoidance Agreement. Appeals Raise Questions Whether Payment to US Satellite Company Constitutes Royalty Under Section 9(1)(vi) of Income-tax Act, 1961 and Article 12 of Treaty, and Whether Retrospective Explanations 5/6 Apply for TDS Under Section 195.
8 May 2025The appeals before the High Court of Judicature at Bombay concerned common substantial questions of law relating to withholding tax obligations on pay...
