India-UK DTAA Case: No Royalty Income Recognized as Broadcasting Rights Licensed Separately; Assessee Only Produced Content.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....Nature of receipt under the head ‘fees for technical services’ (FTS)/Royalty - India-UK DTAA - The job of the assessee ends upon the production of the program content and the broadcasting is carried out by some other entity to which license was given by the BCCI. - the question of transfer of all or any right does not arise in the facts and circumstances of the instant case - No royalty income - AT....