Following the  order of the earlier year the  Tribunal held that there was no transfer of copyright, title or ownership interest from the assessee to the Indian company, that broadcast reproduction right was distinct and separate from copyright, and that, therefore, the distribution revenue received by the assessee from W towards the grant of distribution rights of its channels constituted business income, not royalty. The additions made by the Assessing Officer is  deleted.(AY. 2020-21, 2021-22)