Treaty between India and Thailand – Indian decision that payment for the facility of satellite up-linking and telecasting programmes is not royalty

The Income Tax Appellate Tribunal (ITAT) delivered its decision on 29 August 2012 in the case of Channel Guide India Limited v. ACIT (TS-662-ITAT-2012) that consideration for satellite up-linking facilities and telecasting programmes cannot be treated as an income chargeable to tax in the hands of the recipient under the Income Tax Act, 1961 (ITA). Therefore, there was no disallowance of such expenses in the hands of Channel Guide India Limited for not complying with the provisi…