https://www.taxtmi.com/caselaws?id=379177 Subscription and distribution receipts from telecasting channels were held not to constitute royalty under section 9(1)(vi) of the Income-tax Act or Article 12 of the India-Singapore treaty. The receipts were linked only to distribution of broadcast signals, not to any transfer or use of copyright in literary, artistic, scientific works, cinematograph films, or sound recordings. As the broadcaster did not part with copyright, the consideration fell outside the statutory and treaty definition of royalty. The receipts were therefore taxable as business income, and the revenue's appeal was rejected. en-us Tue, 23 Apr 2019 00:00:00 +0530 Thu, 06 Aug 2026 17:05:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=379177 Subscription and distribution receipts from telecasting channels were held not to constitute royalty under section 9(1)(vi) of the Income-tax Act or Article 12 of the India-Singapore treaty. The receipts were linked only to distribution of broadcast signals, not to any transfer or use of copyright in literary, artistic, scientific works, cinematograph films, or sound recordings. As the broadcaster did not part with copyright, the consideration fell outside the statutory and treaty definition of royalty. The receipts were therefore taxable as business income, and the revenue's appeal was rejected. Case-Laws Income Tax Tue, 23 Apr 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=379177