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2023 (2) TMI 305 - AT - Income TaxIncome deemed to accrue or arise in India - receipt from Satellite Transmission Services - Royalty receipts as defined in Explanation II to section 9(1)(vi) of the Act and Article 12(3) of India – USA Double Taxation Avoidance Agreement (DTAA) - HELD THAT:- As decided in assessee own case [2019 (4) TMI 1426 - ITAT DELHI] receipts from Satellite Transmission Services cannot be treated as royalty, hence, not taxable at the hands of the assessee in India. Accordingly, addition made is deleted. Appeal of assessee allowed.
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