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Sum received by NR towards granting distribution rights of TV channel to Indian Co. is business income & not royalty

October 13, 2020[2020] 120 taxmann.com 155 (Delhi - Trib.)
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INTERNATIONAL TAXATION : Advertisement and distribution revenue received by assessee a US based broadcasting company for granting distribution rights of products (Channels, interactive entertainment services and entertainment mobile telecommunications)to an Indian Company, whereby copyright in content always remained with assessee and at no point of time; same was transferred either to Indian company or the sub-distributor and Indian company acted as an exclusive distributor of such rights to cable operators and other permitted systems on principal-to-principal basis and broadcasting was sole responsibility of assessee and even content on TV Channel could not be changed by any party except for assessee, would not be taxable as 'royalty', albeit it was a business income of assessee

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