https://www.taxtmi.com/caselaws?id=241550 A 99-year irrevocable transfer of exclusive world negative, satellite, broadcasting and allied exploitation rights was treated as a transfer in the nature of sale, not a mere licence to use copyright. The court noted that the assignee could further assign the rights and that the absence of geographical restriction supported the conclusion that the consideration was for sale of cinematographic film rights, falling outside royalty under Explanation 2(vi) and within the exclusion in Explanation 2(v) to Section 9(1) of the Income-tax Act, 1961. The payments therefore did not attract tax deduction at source under Section 194J, and the corresponding disallowance under Section 40(a)(ia) was unsustainable. en-us Tue, 03 Dec 2013 00:00:00 +0530 Fri, 06 Sep 2019 10:12:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=241550 A 99-year irrevocable transfer of exclusive world negative, satellite, broadcasting and allied exploitation rights was treated as a transfer in the nature of sale, not a mere licence to use copyright. The court noted that the assignee could further assign the rights and that the absence of geographical restriction supported the conclusion that the consideration was for sale of cinematographic film rights, falling outside royalty under Explanation 2(vi) and within the exclusion in Explanation 2(v) to Section 9(1) of the Income-tax Act, 1961. The payments therefore did not attract tax deduction at source under Section 194J, and the corresponding disallowance under Section 40(a)(ia) was unsustainable. Case-Laws Income Tax Tue, 03 Dec 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=241550