Payment by Google India to Google Ireland for Purchase of Online Advertisement Space for Onward Resale to Indian Advertisers not “Royalty”: ITAT

Google India - Payment - Google Ireland - Online Advertisement Space - Purchase of Online Advertisement Space - Resale to Indian Advertisers - Indian Advertisers - Royalty - taxscan

The Bangalore bench of the Income Tax Appellate Tribunal (ITAT) has recently held that payment by Google India to Google Ireland for the purchase of online advertisement space for onward resale to Indian advertisers does not amount to Royalty as per Article 12(3)(a) of India-Ireland Double Taxation Avoidance Agreement (DTAA). A wholly owned subsidiary of…

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