https://www.taxtmi.com/caselaws?id=798492 Consideration for live telecast rights in a composite cricket media-rights agreement is not royalty because a live sporting event is not a pre-existing copyrighted work and no copyright is transferred. Consideration attributable to non-live or repeat telecast rights is royalty, as it relates to the use of copyright. Where tax was required but not deducted, only the royalty component is disallowable under the withholding-tax provisions. Applying the established live-to-non-live viewership ratio, 93% of the payment attributable to live broadcasts is not disallowable, while 7% attributable to non-live broadcasts is royalty and is disallowable. en-us Thu, 03 Sep 2026 00:00:00 +0530 Tue, 08 Sep 2026 08:42:21 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=798492 Consideration for live telecast rights in a composite cricket media-rights agreement is not royalty because a live sporting event is not a pre-existing copyrighted work and no copyright is transferred. Consideration attributable to non-live or repeat telecast rights is royalty, as it relates to the use of copyright. Where tax was required but not deducted, only the royalty component is disallowable under the withholding-tax provisions. Applying the established live-to-non-live viewership ratio, 93% of the payment attributable to live broadcasts is not disallowable, while 7% attributable to non-live broadcasts is royalty and is disallowable. Case-Laws Income Tax Thu, 03 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=798492