GIPL's Payments to Google Ireland for Ad Space Not Royalties, No Tax Deduction Required u/s 9(1)(vi) & Article 12(3)(a.

TDS u/s 195 - As decided on payment made by GIPL to M/s. Google Ireland Ltd. for purchase of online advertisement phase for onward resale to India advertisers, in terms of distribution agreement dated 12.12.2005, were not in nature of royalty as defined u/s 9(1)(vi) of the Act read with Article 12(3)(a) of TTA between India and Ireland and observed that GIPL was not an assessee in default u/s 201 of the Act, for not deducting the tax at source - AT .....

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