2015 (6) TMI 1174

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... e's own case when the payment received by the recipient Company is not royalty, the same would also not be royalty in the hands of payee. Thus, no substantial questions of law arises for our consideration. See SET SATELLITE (SINGAPORE) PTE LTD. VERSUS DEPUTY DIRECTOR OF INCOME-TAX, INTERNATIONAL TAXATION AND ANOTHER [2008 (8) TMI 96 - BOMBAY HIGH COURT] - INCOME TAX APPEAL NO. 1347 OF 2013 - - - .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... withholding tax? 3 The Tribunal by the impugned order dismissed the Revenue's appeal on the issue framed for our consideration by the following its decision rendered on 13th April, 2010 in respect of the Nonresident Company namely Set Satellite (Singapore) Pte. Limited i.e. the recipient of the payment. The Tribunal held that amount received by the recipient Company i.e. Set Satellite (Si .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X