Distribution fees paid by Google India to Google Ireland doesn’t attract TDS u/s. 195

Google India Private Ltd. Vs ACIT (ITAT Bangalore) ITAT Bangalore held that distribution fees paid by Google India Private Ltd. (Google India) cannot be treated as DAPE (Dependent Agent Permanent Establishment) of Google Ireland Ltd (Google Ireland). Accordingly, distribution fees paid by Google India to Google Ireland doesn’t attract TDS u/s. 195. Facts- The case was selected for scrutiny and notice u/s. 143(2) was duly served on the assessee. TPO accepted the international transaction of the assessee with its AE to be at arm’s length. AO made the additions with respect to deduction of te...