S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty Deduction at source-Non-resident-Sponsorship agreement-Payment for right to use and display event marks-Having non-exclusive right to use footage relating to events or matches which recipients owned-Not royalty-Allowed refund of excess tax-DTAA-India-Singapore. [S. 195 , Art. 7(1), 12(3)]