Sum received by Warner Bros. for distribution of films in India isn't 'royalty'; ITAT follows previo

IT/ILT : Where assessee, a US based company, engaged in distribution of cinematographic films, received certain amount from its divisional office on account of distribution of films in India, following order passed by Tribunal in assessee's own case relating to earlier assessment years, amount in question could not be taxed as royalty within meaning of Act or DTAA and, at same time, it could not be taxed as 'business income' because assessee did not have Permanent Establishment in India