ITAT Mumbai Deletes Tax Addition Since UAE Consultancy Firm Had No PE in India

Booz & Company (ME) FZ-LLC Vs DDIT (International Taxation) (ITAT Mumbai) AAR Ruling Cannot Be Sole Basis to Hold Existence of Permanent Establishment; No Service PE Created as Employees Worked Less Than Nine Months in India; Fees From Indian AE Not Taxable Due to Absence of Fixed Place PE in India; ITAT Rejects Taxability of Consultancy Receipts Since Indian Entity Was Only Service Recipient; Foreign Consultancy Income Held Non-Taxable as DTAA Conditions for PE Were Not Met; ITAT Says PE Determination Requires Independent Examination of Facts and DTAA Provisions; No Dedicated Office Space...