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    <title>2024 (1) TMI 21 - ITAT DELHI</title>
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    <description>ITAT Delhi held that broadcasting live events does not constitute copyright work, and payments for live broadcasting rights cannot be taxed as royalty under section 9(1)(vi). The tribunal distinguished between live and non-live rights, ruling that when agreements clearly bifurcate consideration, the Department cannot treat live rights payments as part of a bouquet of rights. Additionally, payments to overseas rights holders were not for satellite use or any defined process under the Act. The AO erred in treating remittances as royalty payments, and the assessee&#039;s appeal was allowed.</description>
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      <title>2024 (1) TMI 21 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=447622</link>
      <description>ITAT Delhi held that broadcasting live events does not constitute copyright work, and payments for live broadcasting rights cannot be taxed as royalty under section 9(1)(vi). The tribunal distinguished between live and non-live rights, ruling that when agreements clearly bifurcate consideration, the Department cannot treat live rights payments as part of a bouquet of rights. Additionally, payments to overseas rights holders were not for satellite use or any defined process under the Act. The AO erred in treating remittances as royalty payments, and the assessee&#039;s appeal was allowed.</description>
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      <pubDate>Tue, 26 Dec 2023 00:00:00 +0530</pubDate>
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