https://www.taxtmi.com/caselaws?id=784048 Payment for global partnership and advertising rights was treated in part as royalty because the agreement granted not only advertising space but also a substantive right to use the ICC Mark and Event Mark in the licensed territory. The use of official status and related promotional rights supported characterisation under the Income-tax Act and the Indo-Singapore DTAA, and the attempt to describe trademark use as merely incidental was rejected. The apportioned split between advertisement value and trademark royalty was accepted, with withholding tax sustained on the royalty component. en-us Wed, 24 Dec 2025 00:00:00 +0530 Sat, 27 Dec 2025 08:06:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784048 Payment for global partnership and advertising rights was treated in part as royalty because the agreement granted not only advertising space but also a substantive right to use the ICC Mark and Event Mark in the licensed territory. The use of official status and related promotional rights supported characterisation under the Income-tax Act and the Indo-Singapore DTAA, and the attempt to describe trademark use as merely incidental was rejected. The apportioned split between advertisement value and trademark royalty was accepted, with withholding tax sustained on the royalty component. Case-Laws Income Tax Wed, 24 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784048