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Royalty receipts for live transmission programs were not taxable as royalties under the India-Australia DTAA. The fee received for live transmission cannot be taxed as royalty, following coordinate bench orders affirmed by the Delhi High Court. Regarding the difference in rupee amounts reported by the appellant and Culver Max Entertainment Private Ltd., the issue was restored to the AO for verification due to different exchange rates used. The receipts from Balkrishna Industries Limited were not taxable as royalties under the Income Tax Act or the India-Australia DTAA. The agreements did not indicate that Balkrishna had any claim in the logo or intellectual property beyond the event sponsorship. The consideration was not for transfer or exclusive use of copyrights, but for the right to be part of the Big Bash League as a sponsor. The appeal was allowed.
Royalty receipts for live transmission programs were not taxable as royalties under the India-Australia DTAA. The fee received for live transmission cannot be taxed as royalty, following coordinate bench orders affirmed by the Delhi High Court. Regarding the difference in rupee amounts reported by the appellant and Culver Max Entertainment Private Ltd., the issue was restored to the AO for verification due to different exchange rates used. The receipts from Balkrishna Industries Limited were not taxable as royalties under the Income Tax Act or the India-Australia DTAA. The agreements did not indicate that Balkrishna had any claim in the logo or intellectual property beyond the event sponsorship. The consideration was not for transfer or exclusive use of copyrights, but for the right to be part of the Big Bash League as a sponsor. The appeal was allowed.
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