Tribunal held that the amendment by way of insertion of Expln. 6 to s. 9(1)(vi) defining ‘process’ to include transmission by satellite cannot be read in the definition of royalty in art. 12(3) of the DTAA between India and the USA as there is no similar change in the definition of royalty under the India-USA tax treaty and, therefore, license fees received by the assessee for telecast of live matches did not constitute royalty. Tribunal also held that in any sporting event, ‘live coverage’ of the event has a very large viewership as compared to a recorded broadcast and, therefore, it is appropriate to allocate 10 per cent of the license fee for broadcasting rights towards recorded events and 90 per cent towards ‘live coverage’. (AY. 2013-14 to 2015-16)