https://www.taxtmi.com/caselaws?id=305965 Consideration for live broadcasting of events was held not to fall within royalty under section 9(1)(vi), following the co-ordinate bench view applied in the assessee's own case. On the treaty issue, payments to content providers were held not to arise in India under Article 12(7) of the India-Mauritius treaty because the payer was not a resident of India and the liability was neither incurred in connection with, nor borne by, a permanent establishment in India. The Revenue's challenge therefore failed, and the consequential issue under sections 201(1) and 201(1A) did not survive independently. en-us Fri, 18 May 2012 00:00:00 +0530 Mon, 02 Jan 2023 15:42:44 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=305965 Consideration for live broadcasting of events was held not to fall within royalty under section 9(1)(vi), following the co-ordinate bench view applied in the assessee's own case. On the treaty issue, payments to content providers were held not to arise in India under Article 12(7) of the India-Mauritius treaty because the payer was not a resident of India and the liability was neither incurred in connection with, nor borne by, a permanent establishment in India. The Revenue's challenge therefore failed, and the consequential issue under sections 201(1) and 201(1A) did not survive independently. Case-Laws Income Tax Fri, 18 May 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=305965