Income arising from sub-licensing of non-live feed had been offered to tax as royalty and assessee contended that consideration received in relation to live feeds did not constitute royalty either under Income-tax Act or under India-Singapore Treaty.  Assessing Officer held that entire license fee was taxable as royalty, because it was covered by expression process which included transmission by satellite cable, optic fibre etc.  Dismissing the appeal of the Revenue  the Court held that  in view of decision of High Court in CIT v. Delhi Race Club (1940) Ltd (2015) 228 Taxman 185 (Delhi)(HC)  that a live telecast would not fall within ambit of expression Scientific work. Order of Tribunal is affirmed. (AY.2015-16)