Online marketing payments to non-resident companies like Facebook and AWS not considered royalties u/s 9(1)(vi). No TDS.

Royalty u/s 9(1)(vi) - TDS u/s 195 - Assessee sells its products mainly through online marketing. - In the instant case, the recipients, i.e, M/s Facebook and Rocket Science group only allow the assessee to use their facilities for the purpose of creating advertisement content. The payment made to Amazon Web Services (AWS) is only for using the information technology facilities provided by it, that too the billing would depend upon the extent of usage of those facilities - the payments made by the assessee to the three non-resident companies referred above cannot be considered ad “royalty payments” and hence they do not give rise any income chargeable in India - AT .....

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