https://www.taxtmi.com/caselaws?id=784224 Consideration received for granting only non-exclusive broadcasting rights in cinematographic films, without any transfer of copyright or right to use copyright, does not constitute royalty under section 9(1)(vi) of the Income-tax Act or Article 12(3) of the India-Mauritius DTAA. The statutory carve-out for sale, distribution, or exhibition of cinematographic films also supported the exclusion from royalty treatment. On these facts, the receipt was not taxable as royalty and the related addition was deleted. en-us Wed, 24 Dec 2025 00:00:00 +0530 Wed, 31 Dec 2025 09:17:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784224 Consideration received for granting only non-exclusive broadcasting rights in cinematographic films, without any transfer of copyright or right to use copyright, does not constitute royalty under section 9(1)(vi) of the Income-tax Act or Article 12(3) of the India-Mauritius DTAA. The statutory carve-out for sale, distribution, or exhibition of cinematographic films also supported the exclusion from royalty treatment. On these facts, the receipt was not taxable as royalty and the related addition was deleted. Case-Laws Income Tax Wed, 24 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784224