https://www.taxtmi.com/caselaws?id=783636 Consideration for supplying licensed in-flight entertainment content is examined under the India-UK DTAA and the Income-tax Act as potential royalty and fee for technical services. The analysis states that where no copyright rights are transferred to the airline and the recipient only gets use of the content for exhibition, the payment does not constitute royalty under the treaty, applying the more beneficial treaty position. It also states that, absent any technical knowledge, skill, know-how, or process being made available to the airline, the receipt does not qualify as fee for technical services. The resulting tax addition on these two heads is treated as deleted. en-us Mon, 15 Dec 2025 00:00:00 +0530 Fri, 19 Dec 2025 08:30:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783636 Consideration for supplying licensed in-flight entertainment content is examined under the India-UK DTAA and the Income-tax Act as potential royalty and fee for technical services. The analysis states that where no copyright rights are transferred to the airline and the recipient only gets use of the content for exhibition, the payment does not constitute royalty under the treaty, applying the more beneficial treaty position. It also states that, absent any technical knowledge, skill, know-how, or process being made available to the airline, the receipt does not qualify as fee for technical services. The resulting tax addition on these two heads is treated as deleted. Case-Laws Income Tax Mon, 15 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783636