https://www.taxtmi.com/caselaws?id=431170 A distribution right over channel content that permits retransmission subject to restrictions on alteration does not amount to a transfer of copyright; it is only a broadcasting reproduction right, so the subscription/distribution revenue was not taxable as royalty under section 9(1)(vi) or the treaty provision. Where the revenue was received and offered to tax by the Indian entity, and no part accrued to or was received by the non-resident assessee, no notional attribution could be made on permanent establishment principles. The additions were therefore deleted. en-us Mon, 21 Nov 2022 00:00:00 +0530 Wed, 07 Dec 2022 10:27:58 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=431170 A distribution right over channel content that permits retransmission subject to restrictions on alteration does not amount to a transfer of copyright; it is only a broadcasting reproduction right, so the subscription/distribution revenue was not taxable as royalty under section 9(1)(vi) or the treaty provision. Where the revenue was received and offered to tax by the Indian entity, and no part accrued to or was received by the non-resident assessee, no notional attribution could be made on permanent establishment principles. The additions were therefore deleted. Case-Laws Income Tax Mon, 21 Nov 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=431170