https://www.taxtmi.com/caselaws?id=305986 Receipts from sub-licensing live transmission rights were held not taxable as royalty under the Income-tax Act or the India-Singapore DTAA because royalty under Explanation 2 to section 9(1)(vi) requires a transfer of rights in a copyright or similar protected property. Live telecast or live broadcast was treated as outside copyright protection, which subsists in specified works such as literary, dramatic, musical, artistic works, cinematograph films and sound recordings. The distinction between copyright and broadcasting right was applied to exclude live coverage from the royalty definition, and Explanation 6 on process and satellite transmission was held inapplicable because the assessee was not the transmitter. The addition was deleted. en-us Fri, 20 Mar 2020 00:00:00 +0530 Tue, 03 Jan 2023 21:14:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=305986 Receipts from sub-licensing live transmission rights were held not taxable as royalty under the Income-tax Act or the India-Singapore DTAA because royalty under Explanation 2 to section 9(1)(vi) requires a transfer of rights in a copyright or similar protected property. Live telecast or live broadcast was treated as outside copyright protection, which subsists in specified works such as literary, dramatic, musical, artistic works, cinematograph films and sound recordings. The distinction between copyright and broadcasting right was applied to exclude live coverage from the royalty definition, and Explanation 6 on process and satellite transmission was held inapplicable because the assessee was not the transmitter. The addition was deleted. Case-Laws Income Tax Fri, 20 Mar 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=305986