NGC India Distribution Rights Not Classified as Royalty under Article 12 of India-USA DTAA. No Fees for Included Services.

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....Accrual of income - Royalty - the distribution rights granted by the assessee to NGC India is only a commercial right / Broad Cast reproduction right and not copyright and consequently consideration received by the assessee for the same cannot be treated as royalty or fees for included services under Article 12 of India-USA DTAA - AT....