No royalty under India-Singapore DTAA if liability to pay royalty wasn’t borne by PE of NR payer in

IT/ILT: Where assessee, a Singapore based company, made payment for acquisition of right to broadcast cricket matches, in view of fact that liability to pay said amount was not incurred in connection with its PE in India, following order passed by Tribunal in assessee's own case relating to assessment year 2003-04, it was to be concluded that payment in question was not taxable as 'royalty' having regard to article 12(7) of India-Singapore DTAA