Dismissing the appeal of the Revenue the Tribunal held that the role of the assessee was that agent of Singapore company  where by the assessee was granted access for the purpose of advertisement to be made in the website. The assessee only acted as a conduit for channelizing the funds from the person wanting to advertise to the platform on which such advertisement was to be done, i, e.Google. The person running the advertisement, the person displaying the advertisement and the person using that advertisement were all outside India. In view of this these specified services were not provided to a resident in India. Thus, when the targeted audience and the party paying the online advertisement had no relation in India, the equalisation levy was not attracted. Order of the National Faceless Appeal Centre was affirmed. s (AY. 2018-19)