Addition of receipt not in the nature of royalty is unsustainable in law

BBC World Distribution Ltd Vs ADIT (ITAT Delhi) ITAT Delhi held that revenue received towards to distribute the channel to cable operators, DTH operators, hotels, institutions etc. in India is not in the nature of royalty and hence addition not sustainable. Facts- BBC World News Ltd (in short ‘BBCWN’) is a company incorporated in United Kingdom (UK) and tax resident of UK. BBCWN is the owner of BBC World New Channel. BBCWN has granted non-exclusive global right to BBC World Distribution Limited (In short ‘BBCWD’), the present assessee, to distribute the channel. BBCWD, in turn, has ent...