https://www.taxtmi.com/caselaws?id=203049 A non-resident's Indian liaison office was held to be confined to purchase-related and preparatory activities for export, including assorting diamonds, checking quality and negotiating price before completion of purchase. Those activities did not amount to a physical or qualitative transformation of the goods and remained incidental to procurement. On that basis, the operations fell within the exemption in Explanation 1(b) to section 9(1)(i) of the Income-tax Act, so no income was deemed to accrue or arise in India. The treaty position also barred attribution of profit merely because purchases were made through the alleged PE, and no taxable profit was attributable in India. en-us Fri, 28 Jan 2011 00:00:00 +0530 Mon, 02 May 2011 18:34:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=203049 A non-resident's Indian liaison office was held to be confined to purchase-related and preparatory activities for export, including assorting diamonds, checking quality and negotiating price before completion of purchase. Those activities did not amount to a physical or qualitative transformation of the goods and remained incidental to procurement. On that basis, the operations fell within the exemption in Explanation 1(b) to section 9(1)(i) of the Income-tax Act, so no income was deemed to accrue or arise in India. The treaty position also barred attribution of profit merely because purchases were made through the alleged PE, and no taxable profit was attributable in India. Case-Laws Income Tax Fri, 28 Jan 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=203049