https://www.taxtmi.com/caselaws?id=447621 Payments under a sponsorship arrangement for limited, non-exclusive use of event marks, footage and photographs for advertising and brand promotion were treated as sponsorship consideration, not royalty. The dominant object of the arrangement was publicity and promotion, while any use of trademarks, logos or similar proprietary material was incidental. On that basis, the payment did not fall within royalty under the Income-tax Act or Article 12 of the India-Singapore DTAA, and no tax deduction obligation arose on that characterisation. en-us Tue, 19 Dec 2023 00:00:00 +0530 Tue, 27 Aug 2024 12:22:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=447621 Payments under a sponsorship arrangement for limited, non-exclusive use of event marks, footage and photographs for advertising and brand promotion were treated as sponsorship consideration, not royalty. The dominant object of the arrangement was publicity and promotion, while any use of trademarks, logos or similar proprietary material was incidental. On that basis, the payment did not fall within royalty under the Income-tax Act or Article 12 of the India-Singapore DTAA, and no tax deduction obligation arose on that characterisation. Case-Laws Income Tax Tue, 19 Dec 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=447621