Royalty / Fees for Technical Services (FTS)
CASE LIST
A copyrighted article does not fall within the purview of Royalty (under the Finland DTAA)
- Director of Income Tax vs. Ericsson, 343 ITR 370
- Director of Income Tax vs. M/s. Nokia Networks Oy, [2013] 358 ITR 259 (Delhi) [Summary]
- Director of Income Tax vs. Infrasoft Ltd., (2014) 264 CTR (Del) 329 [Summary]
Payments to Satellite Operators for broadcasting does not qualify as royalties.
- Asia Satellite Telecommunications Co. Ltd. vs. DCIT, [2003] 85 ITD 478 (Del.)
Payment for the transfer of right to broadcast live matches is not royalty.
- ADIT (Intl. Tax) vs. Neo Sports Broadcast Pvt. Ltd., [2011] 133 ITD 468 (Mum.)
Payment for services pursuant to a Data Processing Services Agreement does not constitute FTS
- R.R. Donnelley India Outsource Private Ltd. Case, [2011] 335 ITR 122 (AAR)