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Receipt under Google AdWord Program is Business Profit: ITAT reiterates
Case Law Details
- Case Name
- M/s. Google Ireland Ltd. Vs DCIT (ITAT Bangalore)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2007-08
- Courts
- All ITAT, ITAT Bangalore
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M/s. Google Ireland Ltd. Vs DCIT (ITAT Bangalore)
Conclusion: Google Ireland taxable in India for the advertisements directly placed by the advertisers under AdWord Program as the same constitute business profits.
Held: Assessee-Google Ireland received a sum from Google India Private Limited (GIPL) and a certain sum received from other advertisers towards sale of online ad space in India under AdWord Program which was chargeable to tax as ‘Royalty’ under the Act and the Double Taxation Avoidance Agreement (DTAA). Revenue contended in this petition that the assessment was never made...
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