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2019 (2) TMI 1803 - BOMBAY HIGH COURTRoyalty receipt - payment received by the Assessee from the BCCI - whether payment received by the Assessee from the BCCI for such work, was in the nature of “Fee for technical services” - India UK Double Taxation Avoidance Agreement (DTAA) - HELD THAT:- Tribunal interpreted this definition to hold that to include in the expression royalty, the payment in question should have to be made for the use of or right to use any copyright etc. The Tribunal referred to the decision of the Delhi High Court in the case of CIT v/s. Delhi Race Club Ltd., [2014 (12) TMI 265 - DELHI HIGH COURT] in support of its conclusions. We are in agreement with the view of the Tribunal. Considering the nature of payments received by the Assessee from BCCI and considering the definition of term royalty contained in DTAA between two countries, it cannot be stated that Assessee received payment from the BCCI by way of royalty. There was no copyright vested in the Assessee for which the payment in question was being made. The Assessee merely prepared a coverage of live cricket matches under the contact, for such purpose, awarded by the BCCI. This question is, therefore, not entertained.
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