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Documents citing Pinstorm Technologies P.Ltd, Mumbai vs Department Of Income Tax on 12 August, 2015

International Air Transport ... vs Acit (It), Range 2 (2)(1), Mumbai on 8 January, 2025

14. The facts for the year under consideration being identical, in our view the impugned issue is covered by the above decision of the coordinate bench and 26 ITA Nos. 7416, 7072 & 7117/Mum/2019 International Air Transport Association (Canada) accordingly we hold that the provision of advertising space cannot be considered as royalty. The AO is directed to delete the addition made in this regard.
Income Tax Appellate Tribunal - Mumbai Cites 25 - Cited by 0 - Full Document

International Air Association ... vs Asst Cit (International Taxation) ... on 8 January, 2025

14. The facts for the year under consideration being identical, in our view the impugned issue is covered by the above decision of the coordinate bench and 26 ITA Nos. 7416, 7072 & 7117/Mum/2019 International Air Transport Association (Canada) accordingly we hold that the provision of advertising space cannot be considered as royalty. The AO is directed to delete the addition made in this regard.
Income Tax Appellate Tribunal - Mumbai Cites 25 - Cited by 0 - Full Document

Internatinal Air Transport ... vs Dcit (It) 2(2)(1), Mumbai on 8 January, 2025

14. The facts for the year under consideration being identical, in our view the impugned issue is covered by the above decision of the coordinate bench and 26 ITA Nos. 7416, 7072 & 7117/Mum/2019 International Air Transport Association (Canada) accordingly we hold that the provision of advertising space cannot be considered as royalty. The AO is directed to delete the addition made in this regard.
Income Tax Appellate Tribunal - Mumbai Cites 25 - Cited by 0 - Full Document

International Air Transport ... vs Deputy Commissioner Of Income Tax ... on 29 April, 2025

A similar view had also been arrived at by the ITAT, Mumbai in the case of Pinstorm Technologies Pvt. Ltd. Vs. ITO (2013) 154 TTJ 0173 (Mum). In the said case, it was observed by the tribunal that the amount paid by the assessee to M/s. Google Ireland Ltd. for the services rendered for uploading and display of banner advertisement on its portal was in the nature of business profit on which no tax was deductible at source since the same was not chargeable to tax in India in the absence of any PE. Accordingly, on the basis of our aforesaid observations we are unable to persuade ourselves to subscribe to the characterisation of the consideration received by the assessee for providing advertising space to its customers, as royalty, by the A.O/DRP. As such, the view taken by the lower authorities wherein they had taxed the ve receipts from provision of advertising space as 'royalty' income in the P a g e | 25 ITA No. 3330/Mum/2023 A.Y. 2020-21 International Air Transport Association hands of the assessee is vacated. The Ground of appeal No. 5 is allowed in terms of our aforesaid observations."
Income Tax Appellate Tribunal - Mumbai Cites 27 - Cited by 0 - Full Document
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