Googly for Google - or Not? - Part 1

December 20,2017
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Kishor Phadke (Chartered Accountant)

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  • CA Yogesh Limaye on May 13,2018

    sirji.. in view of Hon k'taka HC - this bench has adjudicated upon the issue afresh. Finally, it has come to almost the same conclusion. Now in all 2 separate division benches have adjudicated precisely same issue for the same assessee for the same year. thus this is more than a SB decision. I think you need to write another article to reconcile this judgment with the issues raised like income from China where there is no entry for Google, IP made available by the senior consultant to his junior for doing his work.

  • Uday Ved on Dec 20,2017

    This is essentially recharacterisation of nature of Revenue/Income - ad revenues being recharactersied as Revenue for licence to use - Is that feasible pre-GAAR era even if that's the case?

  • CA Yogesh Limaye on Dec 20,2017

    Good Analysis. Though very few may agree with it. The examples given clears the understanding.

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