No Equalisation Levy on Google Ad Reimbursements as Services Were Provided to Foreign Subsidiary

Zoho Corporation Private Limited Vs DCIT (Madras High Court) The Madras High Court considered a writ petition challenging the rejection of refund claims relating to equalisation levy paid for financial years 2016-17 and 2017-18. The petitioner, an Indian software product company, had overseas subsidiaries, including a US subsidiary that acted as a reseller of its products in the United States. The US subsidiary availed online advertising services from Google USA through the Google AdWords Program, paid Google directly, and was subsequently reimbursed by the Indian parent company for such marke...