https://www.taxtmi.com/caselaws?id=306360 The Tribunal ruled in favor of the assessee, determining that the royalty income received from Warner Bros Picture India Ltd is not taxable in India. The Tribunal upheld that the income falls under the exclusion provided in Explanation 2(v) to section 9(1)(vi), which excludes consideration for the sale, distribution, or exhibition of cinematographic films from the definition of "royalty." Additionally, it was established that the income is not taxable under the Income Tax Act due to specific provisions excluding such income, and the absence of a Permanent Establishment in India further supported the non-taxability of the royalty as business profit. en-us Thu, 27 Oct 2016 00:00:00 +0530 Tue, 24 Jan 2023 19:59:26 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=306360 The Tribunal ruled in favor of the assessee, determining that the royalty income received from Warner Bros Picture India Ltd is not taxable in India. The Tribunal upheld that the income falls under the exclusion provided in Explanation 2(v) to section 9(1)(vi), which excludes consideration for the sale, distribution, or exhibition of cinematographic films from the definition of "royalty." Additionally, it was established that the income is not taxable under the Income Tax Act due to specific provisions excluding such income, and the absence of a Permanent Establishment in India further supported the non-taxability of the royalty as business profit. Case-Laws Income Tax Thu, 27 Oct 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=306360