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 12.12.2005 with Google Ireland Limited (GIL). As per the agreement, the assessee was appointed as a non-exclusive distributor ...