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Debate on Taxability of Online Ad Space Receipts as 'Royalty' u/s 254(2) of Income Tax Act.

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....Rectification u/s 254(2) - receipt from other advertisers towards sale of online ad space in Inida under AdWord Program is chargeable to tax as 'Royalty - issue is highly debatable and two views are possible. It would not be appropriate to exercise powers u/s.254(2) of the Act as the order does not suffer from any mistake apparent on the face of the record.....

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