Income from product distribution taxable as ‘business income’ not ‘Royalty’

Turner Broadcasting System Asia Pacific Inc. Vs DDIT (ITAT Delhi) Conclusion: Since distributor of the products did not have any right to change the content hence, the revenue derived on account of distribution of the products was business income and under no circumstance, could be held to be royalty. Assessee had already offered income as business income in terms of the MAP, therefore, the income as declared by assessee in accordance with the MAP and accepted by the Department in the earlier years had to be accepted. Held: Appellant-company was a tax resident of the USA. During the relevant a...