https://www.taxtmi.com/caselaws?id=263348 Amounts received for producing and delivering live audio-visual cricket coverage were not taxable as fee for technical services under the India-UK DTAA because the service did not make technical knowledge, skill, know-how, or a technical plan available to the payer. The payer received only the final programme feed, not the ability to independently apply the technology. The same receipts were also not taxable as royalty under the treaty or the Income-tax Act because there was no grant of any right to use copyright, process, or equipment, and no material showed retention of ownership in the content with licensing of such rights. The additions on these grounds failed, and the remaining issues were remanded for fresh consideration, giving partial relief. en-us Wed, 26 Aug 2015 00:00:00 +0530 Tue, 01 Sep 2015 09:06:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=263348 Amounts received for producing and delivering live audio-visual cricket coverage were not taxable as fee for technical services under the India-UK DTAA because the service did not make technical knowledge, skill, know-how, or a technical plan available to the payer. The payer received only the final programme feed, not the ability to independently apply the technology. The same receipts were also not taxable as royalty under the treaty or the Income-tax Act because there was no grant of any right to use copyright, process, or equipment, and no material showed retention of ownership in the content with licensing of such rights. The additions on these grounds failed, and the remaining issues were remanded for fresh consideration, giving partial relief. Case-Laws Income Tax Wed, 26 Aug 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=263348