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    <title>2016 (4) TMI 208 - ITAT MUMBAI</title>
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    <description>Receipts from live audio-video coverage of cricket matches were held not to be fees for technical services because the work only produced a finished live feed and did not make technical knowledge, experience or skill available to the recipient. The agreement&#039;s technical specifications were treated as broadcast quality-control requirements, not a transfer of know-how. The receipts were also held not to be royalty, as they were paid for production of program content and not for use of copyright, equipment, or similar property, with no transfer of rights in the content shown. Given the accepted service permanent establishment, the receipts were to be examined as business income under the India-UK DTAA.</description>
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