https://www.taxtmi.com/caselaws?id=448609 Receipts from live sports transmission were not royalty under Section 9(1)(vi) of the Income-tax Act because a live telecast is not a copyrightable work and broadcast rights are distinct from copyright. The Court also accepted the contractual split between live and non-live transmission, finding no basis to treat live-feed receipts as royalty under clause (v) of Explanation 2. Explanation 6, which deems transmission by satellite and similar technologies to be a process, did not apply because the actual transmission was carried out by another entity. Domestic amendment could not enlarge the scope of the treaty definition of royalty, so the receipts were held not taxable as royalty. en-us Fri, 05 Jan 2024 00:00:00 +0530 Tue, 20 Jan 2026 12:15:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=448609 Receipts from live sports transmission were not royalty under Section 9(1)(vi) of the Income-tax Act because a live telecast is not a copyrightable work and broadcast rights are distinct from copyright. The Court also accepted the contractual split between live and non-live transmission, finding no basis to treat live-feed receipts as royalty under clause (v) of Explanation 2. Explanation 6, which deems transmission by satellite and similar technologies to be a process, did not apply because the actual transmission was carried out by another entity. Domestic amendment could not enlarge the scope of the treaty definition of royalty, so the receipts were held not taxable as royalty. Case-Laws Income Tax Fri, 05 Jan 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=448609