Purchase of online Advertisement space for onward resale to Indian Advertisers did not amount to Royalty as unless the non-resident, who was engaged in sale of online advertisement space, had a PE in India, no portion of receipts earned by it from sale of online advertisement space in India could be brought to tax in India as Act read with the relevant DTAA. Thus, assessee was not  in default u/s 201, for not deducting the tax at source, on the payment in question, under the section 195.

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