Assessee derived more than 97 per cent of its total revenue from advertisement services through its AdWords program worldwide. Revenue initiated reassessment proceedings in case of assessee on basis of orders passed under section 201 and 201(1A) in case of GIPL and passed assessment order holding that receipts from GIPL/other Indian customers for sale of advertisement space was taxable as royalty under Act as well as under treaty provisions.  Tribunal held that the amount received by assessee from sale of advertisement space through its AdWords program could not be brought to tax in India as royalty. (AY. 2007-08)