https://www.taxtmi.com/caselaws?id=219586 The Tribunal ruled in favor of the assessee, a digital advertising and internet marketing company, in a case involving the disallowance of Advertisement expenditure under sec.40(a)(i) for non-deduction of tax at source. The Tribunal held that the payment to Google Ireland Ltd. for advertising services constituted business profit, not royalty, and as there was no Permanent Establishment in India, tax deduction at source was not required. Consequently, the disallowance under sec.40(a)(i) was deleted, allowing the appeal of the assessee. en-us Wed, 18 Jul 2012 00:00:00 +0530 Tue, 11 Sep 2012 17:58:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=219586 The Tribunal ruled in favor of the assessee, a digital advertising and internet marketing company, in a case involving the disallowance of Advertisement expenditure under sec.40(a)(i) for non-deduction of tax at source. The Tribunal held that the payment to Google Ireland Ltd. for advertising services constituted business profit, not royalty, and as there was no Permanent Establishment in India, tax deduction at source was not required. Consequently, the disallowance under sec.40(a)(i) was deleted, allowing the appeal of the assessee. Case-Laws Income Tax Wed, 18 Jul 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=219586