Broadcast Rights Income Not Royalty Without Copyright Transfer

Asia Today Ltd. Vs ADIT (International Taxation) (ITAT Mumbai) Non-Exclusive Film Broadcasting Licence Is Not “Royalty”: ITAT Mumbai Holds ₹1 Cr Film-Rights Receipt of Mauritius Company Not Taxable in India ITAT Mumbai (I Bench) in Asia Today Ltd. vs ADIT (International Taxation) (ITA No. 1403/Mum/2008, AY 2004-05, order dated 24.12.2025) has allowed the assessee’s appeal and held that consideration of ₹1 crore received for granting non-exclusive broadcasting rights of Hindi feature films does not constitute “royalty”, and hence is not taxable in India. The Assessee, a Mauritius-...