https://www.taxtmi.com/caselaws?id=761644 Receipts from sale of online advertisement space and related marketing and distribution arrangements were held not to fall within royalty or fees for technical services under the Income-tax Act and the India-Ireland DTAA. The Tribunal followed binding coordinate Bench rulings in the assessee's own case and connected payer-side appeals, which had already rejected characterisation of the payments as royalty or technical service fees. On that basis, it found no reason to differ from the CIT(Appeals) and upheld the view that the receipts were not taxable in India on these grounds. en-us Mon, 21 Oct 2024 00:00:00 +0530 Wed, 13 Nov 2024 17:19:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=761644 Receipts from sale of online advertisement space and related marketing and distribution arrangements were held not to fall within royalty or fees for technical services under the Income-tax Act and the India-Ireland DTAA. The Tribunal followed binding coordinate Bench rulings in the assessee's own case and connected payer-side appeals, which had already rejected characterisation of the payments as royalty or technical service fees. On that basis, it found no reason to differ from the CIT(Appeals) and upheld the view that the receipts were not taxable in India on these grounds. Case-Laws Income Tax Mon, 21 Oct 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=761644