https://www.taxtmi.com/caselaws?id=65013 A foreign enterprise's Indian liaison offices will not constitute a permanent establishment under the India-Japan tax treaty where their functions are limited to passing information, coordinating communications and other preparatory or auxiliary activities incidental to contract formation. On the facts described, the Revenue's material did not establish trading or sales activity in India, and the regulatory permissions showed the offices were authorised only as liaison offices. In that situation, the treaty definition of permanent establishment prevails over the general deeming rule in section 9(1) of the Income-tax Act, so no business connection taxable in India is made out. en-us Fri, 11 Oct 1991 00:00:00 +0530 Fri, 11 Feb 2011 16:47:27 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=65013 A foreign enterprise's Indian liaison offices will not constitute a permanent establishment under the India-Japan tax treaty where their functions are limited to passing information, coordinating communications and other preparatory or auxiliary activities incidental to contract formation. On the facts described, the Revenue's material did not establish trading or sales activity in India, and the regulatory permissions showed the offices were authorised only as liaison offices. In that situation, the treaty definition of permanent establishment prevails over the general deeming rule in section 9(1) of the Income-tax Act, so no business connection taxable in India is made out. Case-Laws Income Tax Fri, 11 Oct 1991 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=65013