Held, that there was no requirement to deduct tax at source from the advertisement charges paid to F as the main purpose of making payment was only to place advertisements and not to use the facilities provided by F. The payment made did not fall within the meaning of “royalty”. The Assessing Officer was directed to delete the disallowance.(AY. 2012-13 to 2015-16)
Matrimony.Com Ltd. v ACIT (2023)101 ITR 253 (Chennai) (Trib)
S. 40(a)(i) : Amounts not deductible-Deduction at source-Non-resident –Royalty-Income deemed to accrue or arise in India-Payment towards availing of facilities subject to placements of advertisements-Not for license or right to use-Not Royalty-Not liable to deduction of tax at source. [S.9(1)(vi), 195, 201 (1).