The revenue authorities sought to tax the consideration received by the non-resident assessee for granting broadcasting rights of cricket matches as ‘Royalty’ under section 9(1)(vi) and the India-Sri Lanka DTAA. On appeal, the Hon’ble High Court found and held that a live telecast/feed does not involve the transfer of any copyright or derivative exploitation rights. Royalty presupposes enduring benefits, such as the right to record, preserve, and re-telecast the matches in the future. Since the rights granted were strictly confined to the ‘live feed’ of specific matches within the series, the receipts cannot be classified as royalty. Accordingly, the department’s appeal was dismissed.