Google India has been provided access to the IPR, Google Brand ...

Google India's Payments to Google Ireland Classified as Royalties, Taxable in India Under Adwords Programme Rights Access.

October 27, 2017

Case Laws Income Tax AT

Google India has been provided access to the IPR, Google Brand features, secret process embedded in Adwords Programme as tool of the trade for generation of income. Therefore the payment made by the appellant to Google Ireland is royalty and not the business profit and therefore chargeable to tax in India.

View Source

← Previous Next →

Google India has been provided access to the IPR, Google Brand ...

Google India's Payments to Google Ireland Classified as Royalties, Taxable in India Under Adwords Programme Rights Access.

October 27, 2017

Case Laws Income Tax AT

You may also like:

Income taxable in India - Royalty or FTS - PE in India or not? - Assessment of payments made by Google India Pvt. Ltd. (Payer) to Google Ireland Limited (payee) for...

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...

The Appellate Tribunal addressed the issue of characterizing interconnect utility charges (IUC) as 'Royalty' for TDS u/s 195 of the Income Tax Act and India-Japan DTAA....

TDS disallowance u/s 40(a)(i) for non-deduction on overseas payments towards patent fees, reimbursement of official fees and professional fees, treating such payments as...

Income accrued in India - royalty receipt - As noted that the definition of royalty under the ITA, prior to amendment in 2012, as well as the DTAAs under consideration...

Taxability of supply of software - the receipts from supply of software are not taxable in the hands of Intec–Ireland as Royalty under new Ireland tax treaty....

Income taxable in India or not - FTS/FIS - payments received by the assessee from its Indian customers on account of Centralized Services - absence of PE in India - The...

TP adjustment - re-characterization of functionality rejected, agreements relied upon for APA considered. APA applicability and comparables remanded to AO/TPO for fresh...

TDS u/s 195 - payments by resident Indian end-user to non-resident computer software manufacturers/suppliers - payment for software licenses not royalty under Article 12...

Taxability of Income in India - The receipt of IUC charges cannot be taxed as Royalty under Article 13 in India of India-France DTAA. The payment received by the...

Taxable Income in India or not - Royalty receipt - PE in India or not? - amount received towards Marketing Contribution, Priority Club receipts, Reservation...

Accrual of income in India - royalty income - supply of software - absence of PE of the assessee in India - The Tribunal held that, the payments received by the assessee...

Income taxable in India - Taxability of the receipts as “Royalty" - telecom services comprising of interconnectivity services - Once the situs is outside India, then in...

Income deemed to accrue or arise in India - non-resident corporate entity - Taxability of royalty income received by the assessee on subscribers units from original...

TDS u/s 195 - royalty payments or not - Consideration for advertisement is paid to the overseas bank account of Non-resident - the payments made by the assessee the...

Quick Updates: