Held  that a Mauritius based company, paid programming cost, transponder fees, and uplinking charges to US based company for providing facilities of telecasting channels of assessee in India, since said payment was not made for right to use any industrial, commercial or scientific equipment, payment in question would not fall within ambit of’royalty’ as per article 12 of India-USA DTAA. The assessee is not liable to deduct tax at source. (AY. 2013-14)