Assessee, Google Ireland, an Ireland based company, which is  engaged in business of sale of online advertisement space to GIPL and to direct advertisers. Assessing Officer held  that assessee had given marketing and distribution rights of Adwords program to GIPL and income received from sale of online advertisement space was in nature of royalty. He, thus, issued reopening notice on ground that assessee had not offered receipts for tax and income had escaped assessment. CIT(A) deleted the addition. On appeal the   Tribunal in assessee’s own case for assessment year 2007-08 held that payment made by GIPL to assessee is  not in nature of royalty or FTS and, consequently, it could not be brought to tax in hands of assessee. Order of the CIT(A) is affirmed.(AY.2008-09)