TMI Blog2023 (2) TMI 305X X X X Extracts X X X X X X X X Extracts X X X X ..... LD 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. - ITA No.1942/Del/2022 - - - Dated:- 31-1-2023 - SHRI G.S. PANNU, HON BLE PRESIDENT AND SHRI SAKTIJIT DEY, JUDICIAL ME ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ce Agreement (DTAA). 3. Before us, it is an agreed position between the parties that the issue is squarely covered by the decisions of the Tribunal and Hon ble Jurisdictional High Court in assessee s own case in past assessment years. 4. Having perused the material placed before us, we find, this is a recurring issue between the parties from assessment year 2006-07 onwards and has been consi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... coordinate Bench in ITA No.918/Del/2021 for A.Y. 2017-18 which read as under :- 5. We have considered rival submissions and perused materials on record. A reading of the impugned assessment order and the directions of learned DRP would clearly reveal that by relying upon the approach adopted by them in assessee s case in preceding assessment years beginning from assessment year 2006-07 onwa ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 2. In fact, while deciding identical issue arising in assessee s own case in the immediately preceding assessment year, i.e., AY: 2016-17 in ITA No. 4412/Del/2019, dated 20.05.2022, the Tribunal has followed its earlier decision and held that the amount received from Satellite Transmission Services is not taxable in India as royalty. Thus, respectfully following the consistent view of the Tribunal ..... X X X X Extracts X X X X X X X X Extracts X X X X
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