The distribution revenues received by the assessee towards...

The distribution revenues received by the assessee towards granting distribution rights of its channels cannot be taxed as royalty but as business income. Relying on the Tribunal's decision and the High Court of Delhi's ruling, it is held that the subject distribution revenue earned by the assessee should be treated as business income. Since the assessee had already offered the said income as business income in accordance with the Mutual Agreement Procedure (MAP), which was accepted by the Department in earlier years, the additions made by the Assessing Officer for the Assessment Years 2020-21 and 2021-22 are deleted. The assessee's appeal is allowed.