Payment for satellite space hiring isn't FTS or royalty; matter remanded to check if it could be tax

IT/ILT : Where assessee had taken space on transponder through its non-resident subsidiary company 'E' and paid certain amount as transponder fee to 'E', lower authorities were wrong in disallowing transponder fee by applying provisions of section 40(a)(i) only on limited ground that nature of impugned fee was royalty as well as fees for technical services on which tax was required to be deducted