Licence Fees Received Towards Live Transmissions Of Cricket Matches Held In Australia, Not Taxable In India As Royalty

In a recent decision, the Income Tax Appellate Tribunal (ITAT) ruled that license fees for live transmissions of cricket matches between Australia and India do not qualify as royalty under the India-Australia tax treaty. The tribunal emphasized that the payments were for the use of equipment and facilities, not intellectual property rights. This decision contrasts with earlier rulings, underscoring the importance of factual circumstances in determining tax liability. The case highlights evolving interpretations of royalty under international tax treaties.