The Indian Income Tax Appellate Tribunal (ITAT) delivered a ruling dated 11 August 2006 in the case of Deputy Commissioner of Income Tax v. PanAm Sat International Systems Inc. (9 SOT 100) on whether foreign companies providing transponder services are liable to tax in India. (a) The taxpayer, i.e. PanAm Sat International Systems Inc. (henceforth "PanAm") was a US-based company that owned and operated a global network of telecommunication satellite. Several television (TV) channels used PanAm's satellite for the purposes of transmission of images. The TV channels taped the events live, encoded the signals and used uplink facilities to transmit the signals...