Assessee, a film distributor, had paid an amount as Minimum Guarantee Royalty (MGR) for purchase of theatrical distribution rights.AO held that assessee had purchased copyright and said payment would fall within definition of Royalty and failure to deduct TDS as per section 194J would entail disallowance under section 40(a)(ia)  of the Act. CIT(A) deleted the disallowance. On appeal by revenue the Tribunal held that  copyrights are always with producer and distributor is only given right to exhibition of cinematographic films and, hence, such transactions do not attract provisions of  tax deduction at source.  (AY. 2011-12)