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The ITAT held that the receipts from providing advertisement space and business support services to Criteo India were not taxable as royalty/FTS under Article 12 of the India-Singapore DTAA. The assessee did not have a PE in India under Article 5. The advertisement space was purchased from third-party publishers, over which the assessee had no control or possession. The business support services were routine administrative services without any enduring benefit or transfer of technology to Criteo India. The services did not satisfy the 'make available' clause for constituting FTS. The ITAT directed the AO to delete the additions made on these receipts.
The ITAT held that the receipts from providing advertisement space and business support services to Criteo India were not taxable as royalty/FTS under Article 12 of the India-Singapore DTAA. The assessee did not have a PE in India under Article 5. The advertisement space was purchased from third-party publishers, over which the assessee had no control or possession. The business support services were routine administrative services without any enduring benefit or transfer of technology to Criteo India. The services did not satisfy the 'make available' clause for constituting FTS. The ITAT directed the AO to delete the additions made on these receipts.
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