Assessee entered into service agreement with its Irish group company (‘X’) for providing support services for placing advertisements on online portal of its parent company (‘Y’). These services involved administering internal and government’s guidelines in relation to global advertisements before the advertisements could be placed on Y’s web properties and also customer support services post-sales. Thereafter, Assessee and ‘X’ entered into another agreement pursuant to which Assessee became an authorized distributor/reseller of online advertisement space in India. Assessee credited an amount as payable to X under distributor/reseller agreement. AO held that the amount payable was ‘royalty’ and tax was liable to be deducted. Held: I t was observed that the distributor/reseller agreement obligated the assessee to provide certain services which was dischargeable only through services agreement. To execute services agreement, Assessee was given license to use confidential information, technical knowhow, trade mark, brand features, derivative works, etc.  Tribunal held that consideration paid by Assessee was on account of use these intangibles is certainly ‘royalty’ u/s. 9(1)(vi) as well as under Article 12 of DTAA.  (AY. 2007-08 to 2015-16)