https://www.taxtmi.com/caselaws?id=755212 Live transmission receipts were not royalty under the Income-tax Act or the India-Australia tax treaty because the broadcasting arrangement granted live transmission rights rather than an independent copyright-like right. The related foreign-exchange addition was substantially deleted because it largely arose from those non-taxable receipts; only the residual exchange-rate reconciliation issue required limited verification. Sponsorship receipts were also not royalty because the sponsor received only a limited, non-exclusive and purpose-restricted licence to use logos and branding for promotional association, without an independent or exclusive intellectual-property right. Tax additions were substantially deleted, subject to verification of the residual exchange-rate difference. 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 Live transmission receipts were not royalty under the Income-tax Act or the India-Australia tax treaty because the broadcasting arrangement granted live transmission rights rather than an independent copyright-like right. The related foreign-exchange addition was substantially deleted because it largely arose from those non-taxable receipts; only the residual exchange-rate reconciliation issue required limited verification. Sponsorship receipts were also not royalty because the sponsor received only a limited, non-exclusive and purpose-restricted licence to use logos and branding for promotional association, without an independent or exclusive intellectual-property right. Tax additions were substantially deleted, subject to verification of the residual exchange-rate difference. Case-Laws Income Tax Thu, 27 Jun 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=755212