Sale of Online Advertisement Space Not Taxable as Royalty or FTS in India: ITAT Bangalore

Google Ireland Ltd Vs DCIT (IT) (ITAT Bangalore) ITAT Bangalore held that payment made by Google India Pvt. Ltd. to Google Ireland Limited (assessee) for sale of online advertisement space is not taxable in India as the same cannot be regarded as royalty or FTS. Facts- Assessee, Google Ireland Limited (GIL) is a foreign company having its registered office at Ireland. The assessee is involved in the business of sale of online advertisement space to Google India Pvt. Ltd. (GIPL) under Google Reseller agreements dated 12.12.2005 and 1.7.2012 and to direct advertisers. The assessee did not file t...