https://www.taxtmi.com/caselaws?id=765215 The ITAT Mumbai held in favor of the assessee on two key issues. First, the tribunal ruled that Authorized Training Centres (ATCs) could not be treated as dependent agents permanent establishment (DAPE) of the Canadian assessee, as the relationship was principal-to-principal without agency elements. The addition made by treating ATCs as DAPE for distance learning course income was deleted, following the coordinate bench decision in the assessee's own case for AY 2012-13. Second, regarding joining annual fees for IATA clearing house facility and data processing charges, the tribunal applied the principle of mutuality and held these charges were not taxable in India, consistent with the earlier coordinate bench ruling. en-us Wed, 08 Jan 2025 00:00:00 +0530 Tue, 28 Jan 2025 08:24:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=765215 The ITAT Mumbai held in favor of the assessee on two key issues. First, the tribunal ruled that Authorized Training Centres (ATCs) could not be treated as dependent agents permanent establishment (DAPE) of the Canadian assessee, as the relationship was principal-to-principal without agency elements. The addition made by treating ATCs as DAPE for distance learning course income was deleted, following the coordinate bench decision in the assessee's own case for AY 2012-13. Second, regarding joining annual fees for IATA clearing house facility and data processing charges, the tribunal applied the principle of mutuality and held these charges were not taxable in India, consistent with the earlier coordinate bench ruling. Case-Laws Income Tax Wed, 08 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=765215