Fees for live and non-live transmission right not taxable as royalty

Cricket Australia Vs ACIT (ITAT Delhi) ITAT Delhi held that as there is no copyright on live events, the license fees for live and non-live transmission right cannot be taxed as royaty in terms of section 9(1)(vi) of the Income Tax Act. Accordingly, addition deleted. Facts- The case of the assessee was selected for scrutiny. The reason for scrutiny was stated to be high ratio of refund to TDS relating to Section 195 (Business ITR). AO noticed that the assessee did not offer certain income for tax i.e. license fee for live and non-live transmission rights of INR 5,81,43,665/- and tournament fee...