https://www.taxtmi.com/caselaws?id=419030 Exclusive distribution receipts received by a non-resident for granting Indian distribution rights were held not to be royalty because the agreement did not transfer copyright or any right to use copyright. The assessee retained ownership of the content and copyright, while the Indian distributor was only authorised to receive, promote, market, distribute and sub-distribute the channel products. The receipts were therefore treated as business income, supported by earlier co-ordinate bench and High Court guidance on subscription and distribution income, and by consistent treatment under the mutual agreement procedure in prior years. The additions made by the Assessing Officer were deleted. en-us Thu, 17 Feb 2022 00:00:00 +0530 Tue, 01 Mar 2022 10:34:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=419030 Exclusive distribution receipts received by a non-resident for granting Indian distribution rights were held not to be royalty because the agreement did not transfer copyright or any right to use copyright. The assessee retained ownership of the content and copyright, while the Indian distributor was only authorised to receive, promote, market, distribute and sub-distribute the channel products. The receipts were therefore treated as business income, supported by earlier co-ordinate bench and High Court guidance on subscription and distribution income, and by consistent treatment under the mutual agreement procedure in prior years. The additions made by the Assessing Officer were deleted. Case-Laws Income Tax Thu, 17 Feb 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=419030