Google India payments to Google Ireland were not royalties and not subject to withholding tax, the Income Tax Appellate Authority (ITAT) said on Friday. The order was passed by the Bengaluru bench of the ITAT, which set aside its 2018 order and said that such transfer of money was not a royalty.

source https://gadgets360.com/internet/news/google-india-payments-ireland-withholding-tax-income-tax-apellate-authority-bengaluru-3454515#rss-gadgets-all