https://www.taxtmi.com/caselaws?id=75018 Title sponsorship payments and associated branding benefits did not constitute royalty under Article 13(3)(c) of the India-Canada DTAA because the arrangement conferred no transfer of copyright or right to use copyright. Royalty under the treaty applies only where consideration is paid for use of, or right to use, the specified intellectual property rights covered by Article 13(3). As the sponsorship rights were limited to promotional and branding benefits described in the agreement schedule, the payment fell outside the treaty royalty definition. The Tribunal's view in favour of the assessee was upheld and the revenue's royalty contention failed. en-us Fri, 19 Feb 2010 00:00:00 +0530 Fri, 01 Feb 2013 10:36:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=75018 Title sponsorship payments and associated branding benefits did not constitute royalty under Article 13(3)(c) of the India-Canada DTAA because the arrangement conferred no transfer of copyright or right to use copyright. Royalty under the treaty applies only where consideration is paid for use of, or right to use, the specified intellectual property rights covered by Article 13(3). As the sponsorship rights were limited to promotional and branding benefits described in the agreement schedule, the payment fell outside the treaty royalty definition. The Tribunal's view in favour of the assessee was upheld and the revenue's royalty contention failed. Case-Laws Income Tax Fri, 19 Feb 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=75018