https://www.taxtmi.com/caselaws?id=755212 Consideration for live transmission rights was treated as not constituting royalty under the Income-tax Act and the India-Australia tax treaty because the arrangement granted only transmission rights, not an independent copyright-like interest. The foreign exchange difference addition was largely linked to those receipts and was therefore reduced, with the remaining reconciliation issue sent back for limited verification. Sponsorship receipts under the commercial partnership agreement were likewise held not to be royalty, as the sponsor received only a limited, non-exclusive and purpose-restricted licence to use logos and branding for promotion, without any transfer of an exclusive intellectual property right. The article states that royalty arises only where there is an independent transfer of copyright-like or exclusive IP rights. en-us Thu, 27 Jun 2024 00:00:00 +0530 Mon, 08 Jul 2024 20:41:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=755212 Consideration for live transmission rights was treated as not constituting royalty under the Income-tax Act and the India-Australia tax treaty because the arrangement granted only transmission rights, not an independent copyright-like interest. The foreign exchange difference addition was largely linked to those receipts and was therefore reduced, with the remaining reconciliation issue sent back for limited verification. Sponsorship receipts under the commercial partnership agreement were likewise held not to be royalty, as the sponsor received only a limited, non-exclusive and purpose-restricted licence to use logos and branding for promotion, without any transfer of an exclusive intellectual property right. The article states that royalty arises only where there is an independent transfer of copyright-like or exclusive IP rights. Case-Laws Income Tax Thu, 27 Jun 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=755212