https://www.taxtmi.com/caselaws?id=360332 The Tribunal concluded that payments made by the appellant to Google Ireland Limited constituted "royalty" under the Income Tax Act and DTAA with Ireland. It held that Google India Private Limited was not a Permanent Establishment of Google Ireland Limited. The Tribunal directed a fresh Transfer Pricing analysis and rejected the disallowance under Section 40(a)(i). It upheld the validity of the assessment reopening, remanded the profit attribution issue, and directed the re-computation of deduction under Section 10A. The Tribunal rejected additional grounds for deduction and confirmed the levy of interest under relevant sections. en-us Fri, 11 May 2018 00:00:00 +0530 Mon, 10 Aug 2026 17:57:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=360332 The Tribunal concluded that payments made by the appellant to Google Ireland Limited constituted "royalty" under the Income Tax Act and DTAA with Ireland. It held that Google India Private Limited was not a Permanent Establishment of Google Ireland Limited. The Tribunal directed a fresh Transfer Pricing analysis and rejected the disallowance under Section 40(a)(i). It upheld the validity of the assessment reopening, remanded the profit attribution issue, and directed the re-computation of deduction under Section 10A. The Tribunal rejected additional grounds for deduction and confirmed the levy of interest under relevant sections. Case-Laws Income Tax Fri, 11 May 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=360332