Distribution Revenue from US Broadcasting Company not Taxable as “Royalty” under India-US DTAA

The ITAT ruled that distribution revenue received by an Indian company from a US broadcasting company does not constitute royalty under the India-US Double Taxation Avoidance Agreement (DTAA). The decision clarifies that distribution revenue, in this case, pertains to business income and is not subject to tax in India due to the nature of the agreement. This ruling provides clarity on the tax treatment of cross-border broadcasting revenue, highlighting the distinction between royalty and business income under DTAA.