IFE Content Is Not Royalty: ITAT Delhi Applies DTAA Override Deletes Tax on In-Flight Entertainment Fees

Anuvu UK Operations Limited Vs DCIT (ITAT Delhi) IFE Content Is Not Royalty: ITAT Delhi Applies DTAA Override Deletes Tax on In-Flight Entertainment Fees Delhi ITAT held that fees received for providing in-flight entertainment (IFE) content to Indian airlines are neither royalty nor fees for technical services (FTS) under the India-UK DTAA. The Tribunal noted that the assessee merely procured licensed audio-visual content and undertook activities such as encoding and integration for display on IFE systems, without transferring any copyright or technical know-how to the airline. Relying on its...