Payment by Google India to Google Ireland is not Royalty/ FTS hence TDS not deductible

Google Ireland Ltd. C/o. PricewaterhouseCoopers Pvt. Ltd. Vs DCIT (IT)  (ITAT Bangalore) ITAT Bangalore held that that the payment made by GIPL (Google India Pvt. Ltd.) to GIL (Google Ireland Limited) is not in the nature of Royalty or FTS under the Act. Accordingly, TDS under section 195 of the Income Tax Act not deductible. Facts- The 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 distribution agreement dated 12.12.2005. ...