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ITAT quashed assessment order for AY 2015-16 as notice u/s 148 issued on June 28, 2021 was barred by limitation under amended provisions of section 149(1), not covered under TOLA. On merits, ITAT held license fees for live broadcasting rights do not constitute royalty under DTAA as Explanation-6 to Section 9(1)(vi) defining 'process' was not incorporated in treaty. However, for bundled contracts containing both live and recorded content, ITAT modified apportionment from assessee's claim of 5% recorded/95% live to 10% recorded/90% live coverage, with only recorded portion taxable as royalty. AO directed to apply correct tax rates distinguishing between resident and non-resident payers per treaty provisions.
ITAT quashed assessment order for AY 2015-16 as notice u/s 148 issued on June 28, 2021 was barred by limitation under amended provisions of section 149(1), not covered under TOLA. On merits, ITAT held license fees for live broadcasting rights do not constitute royalty under DTAA as Explanation-6 to Section 9(1)(vi) defining 'process' was not incorporated in treaty. However, for bundled contracts containing both live and recorded content, ITAT modified apportionment from assessee's claim of 5% recorded/95% live to 10% recorded/90% live coverage, with only recorded portion taxable as royalty. AO directed to apply correct tax rates distinguishing between resident and non-resident payers per treaty provisions.
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