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ITAT ruled on two key taxation matters involving cross-border services. Regarding distance learning courses, the Tribunal determined that Authorized Training Centers (ATCs) operated independently on a principal-to-principal basis rather than as Dependent Agent Permanent Establishment (DAPE) of the foreign assessee. Following precedent from AY 2012-13, the addition made by treating ATCs as DAPE was deleted. On the second issue concerning IATA Clearing House (ICH) facility fees and data processing charges, ITAT held these were not taxable in India based on the principle of mutuality. The Tribunal found data processing charges for iiNet and weblink services were similar to ICH facility fees, and therefore not attributable as income to Indian branches.
ITAT ruled on two key taxation matters involving cross-border services. Regarding distance learning courses, the Tribunal determined that Authorized Training Centers (ATCs) operated independently on a principal-to-principal basis rather than as Dependent Agent Permanent Establishment (DAPE) of the foreign assessee. Following precedent from AY 2012-13, the addition made by treating ATCs as DAPE was deleted. On the second issue concerning IATA Clearing House (ICH) facility fees and data processing charges, ITAT held these were not taxable in India based on the principle of mutuality. The Tribunal found data processing charges for iiNet and weblink services were similar to ICH facility fees, and therefore not attributable as income to Indian branches.
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