India-Singapore Tax Treaty: 25% of Licensee Fee from Set Satellite Deemed for Non-Live Content in "Live" Feeds.

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....Income deemed to accrue or arise in India - “Live” Feed or “modified” Feed - Allocation/apportionment of the Licensee Fee income - receipts from Set Setellite Singapore Pte. Ltd. (SET) - benefit of India Singapore Tax Treaty - 25% of Licensee Fee is fair estimation of the Licensee Fee attributable to the Non-Live Exhibitions and recorded content in “Live” Feed. There is no material placed on record by both the sides to arrive at the more precise or better estimation/apportionment. - AT....