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Right Florists - Google Ads

Income Tax Appellate Tribunal·2013·TDS
Facts

Indian advertiser paying Google for ad placements.

Issue

TDS on online advertising payments to non-resident search engines.

Held

No TDS - no PE in India and no royalty character. (Pre-equalisation levy era.)

Ratio

Cross-border digital advertising without PE is not taxable in India under standard DTAA. Equalisation levy framework subsequently introduced to capture such transactions.

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