Royalty u/s 9(1)(vi): Broadcasting rights for live event not chargeable to tax as royalty

Lex Sportel Vision Pvt. Ltd. Vs ITO (ITAT Delhi)

ITAT Delhi held that broadcasting “Live events” does not amount to a work in which copyright subsists i.e., “Live Rights”, is not “copyright” and therefore any payment made thereto can’t be said to be chargeable to tax as royalty under section 9(1)(vi).

Facts- The assessee company engaged in the business of broadcasting or sub-licensing right to broadcast, sport events e.g., golf, cricket, soccer etc. on live a

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