No tax on distribution revenue received as ‘Royalty’ if same already offered as income under MAP

Cable News Network Inc Vs DCIT (ITAT Delhi)

Conclusion: Distribution revenue earned by assessee had already offered income as business income in terms of the Mutual Agreement Procedure (MAP) holding that 10% of the advertising and subscription revenue received from India should be deemed to be the net profit chargeable to tax in India, therefore, the additions made by AO were deleted.

Held: Assessee was a non-resident corporate entity, incorporated in the USA and a tax resident of tha

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