Sponsorship Payments for ICC Cricket Events Not Taxable as Royalty Income in India Under Tax Law and DTAA.

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....Income taxable in India - Royalty u/s. 9 and/or under Article- 12 of India - payments made in terms of Sponsorship Agreement - Singapore, DTAA - sponsorship of the ICC Cricket Events - such payments cannot be considered as royalty in the hands of recipient u/s. 9(1)(vi) - AT....