Equalization levy not applicable on person merely acting as conduit

DCIT Vs Prakash Chandra Mishra (ITAT Jaipur) ITAT Jaipur held that equalization levy not applicable as role of the assessee is merely conduit between the entity carrying out the advertisement and Google. The ultimate benefit of such advertisement is not desired by the assessee. Facts- It was noticed by the assessing officer, that the assessee has debited a sum of Rs. 8,89,35,558/- being online advertisement (adwords) charges paid to M/s. Google Asia Pacific Pte. Ltd., Singapore, a non-resident having no permanent enterprise(PE) in India. Since the payment has been made to a non-resident by the...