Sale of online advertisement space is not taxable if non-resident not has PE in India

Google India Private Limited Vs DCIT (International Taxation) (ITAT Bangalore)

ITAT Bangalore held that unless the non-resident, who is engaged in sale of online advertisement space, has a PE in India, no portion of receipts earned by it from sale of online advertisement space in India can be brought to tax in India as Act read with the relevant DTAA.

Facts- The assessee, Google India Private Limited, had entered into Google AdWords Program Distribution Agreement dated 12.

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