The assessee, a tax resident of Ireland, received consideration from its Indian subsidiary towards the sale of online advertisement space. The Revenue sought to tax the receipts as royalty/fees for technical services pursuant to reassessment proceedings. Following its earlier decision in the assessee’s own case, the Tribunal held that in the absence of a Permanent Establishment in India, the receipts from sale of online advertisement space were not taxable in India under the Act or the India-Ireland DTAA. Consequently, the payments could not be characterised as royalty or fees for technical services, and the additions were deleted. (AY. 2013-14 to 2016-17)