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Equalization Levy Not Applicable u/s 40(a)(ib) When Ad Targeting Has No Connection to India.

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....Addition u/s. 40(a)(ib) - non-charging of Equalization levy - when the intention of levy is related to the targeted audience and party paying the online advertisement has no relation in India, EL is not attracted in the set of present facts and circumstance placed before us - AT....

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