Sum paid to acquire rights of telecasting from outside India, in absence of its link with PE in Indi

IT/ILT: Sum paid to acquire rights of telecasting cricket matches from outside India had no connection with the marketing activities carried out through Permanent Establishment ('PE') of assessee in India - Thus, there was no economic link between the payments - The liability to pay royalty had not been incurred in connection with and was not borne by the PE of the payer in India -Thus, impugned payments couldn't be deemed as royalty in view of Article 12(7) of India-Singapore DTAA