https://www.taxtmi.com/caselaws?id=399271 Exclusive distribution and related commercial rights, without any transfer of copyright or permission to copy, modify, or alter channel content, were treated as falling within broadcast reproduction rights rather than royalty. The treaty definition of royalty was not expanded by the retrospective domestic amendment, so the receipts could not be taxed as royalty on that basis. Consistency with earlier years, where the same treatment had been accepted under the mutual agreement procedure, also supported the position. The distribution revenue was therefore taxable as business income. en-us Wed, 30 Sep 2020 00:00:00 +0530 Wed, 07 Oct 2020 11:55:38 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=399271 Exclusive distribution and related commercial rights, without any transfer of copyright or permission to copy, modify, or alter channel content, were treated as falling within broadcast reproduction rights rather than royalty. The treaty definition of royalty was not expanded by the retrospective domestic amendment, so the receipts could not be taxed as royalty on that basis. Consistency with earlier years, where the same treatment had been accepted under the mutual agreement procedure, also supported the position. The distribution revenue was therefore taxable as business income. Case-Laws Income Tax Wed, 30 Sep 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=399271