https://www.taxtmi.com/caselaws?id=773430 Live broadcasting receipts were analysed as distinct from copyright in a pre-existing work, so payments for live telecast rights were not treated as royalty under section 9(1)(vi) or Article 12 of the India-USA DTAA. The domestic expansion in Explanation 6 could not enlarge the treaty definition absent a corresponding amendment. Where contracts bundled live and recorded or ancillary rights, the consideration required reasonable apportionment on the contract facts, and the Tribunal reduced the live component allocation from 95:5 to 90:10. The reassessment notice for Assessment Year 2015-16 was also treated as time-barred under the applicable limitation framework, and the reassessment was quashed. en-us Wed, 18 Jun 2025 00:00:00 +0530 Thu, 19 Jun 2025 11:21:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=773430 Live broadcasting receipts were analysed as distinct from copyright in a pre-existing work, so payments for live telecast rights were not treated as royalty under section 9(1)(vi) or Article 12 of the India-USA DTAA. The domestic expansion in Explanation 6 could not enlarge the treaty definition absent a corresponding amendment. Where contracts bundled live and recorded or ancillary rights, the consideration required reasonable apportionment on the contract facts, and the Tribunal reduced the live component allocation from 95:5 to 90:10. The reassessment notice for Assessment Year 2015-16 was also treated as time-barred under the applicable limitation framework, and the reassessment was quashed. Case-Laws Income Tax Wed, 18 Jun 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=773430