2025 (5) TMI 883

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....e-tax Act, 1961 (hereinafter referred to as "the Act") dated 08.02.2020 by the Assessing Officer, CPC, Bangalore (hereinafter referred to as "ld. AO"). 2. The only effective issue to be decided in this appeal is challenging the disallowance of Rs. 7,64,18,432/- u/s 40(a)(ib) of the Act in respect of equalization levy for online advertisement. 3. We have heard the rival submissions and perused the material available on record. The return of income for AY 2018-19 was filed belatedly by the assessee on 31.03.2019 declaring total income of Rs. 80,75,700/-. The ld CPC made addition of Rs. 7,64,18,432/- u/s 40(a)(ib) of the Act on account of non compliance with the provisions of Chapter VIII of the Finance Act, 2016 with regard to equalizat....

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....sident having a permanent establishment in India. (2) The equalisation levy under sub-section (1) shall not be charged, where- (a) the non-resident providing the specified service has a permanent establishment in India and specified service is effectively connected with such permanent establishment; (b) the aggregate amount of consideration for specified service received or receivable in a previous year by the non-resident from a person resident in India and carrying on business or profession, or from a non-resident having a permanent establishment in India, does not exceed one lakh rupees; or (c) where the payment for the specified service by the person resident in India, or the permanent establishment i....