https://www.taxtmi.com/caselaws?id=204939 A liaison office that performed vendor identification, quality control, production monitoring, price review, compliance checks and procurement coordination was held to do more than mere purchase activity. On that basis, its Indian operations were treated as creating a business connection, and income attributable to those operations was regarded as accruing or arising in India. The purchase-only statutory exclusion did not apply because the activities were not confined to buying goods for export. The office was also treated as a permanent establishment under the treaty, since it was a fixed place through which business was carried on and was not limited to preparatory, auxiliary, or information-collection functions; the attributable profits were therefore taxable in India. en-us Mon, 08 Aug 2011 00:00:00 +0530 Fri, 04 Nov 2011 16:53:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=204939 A liaison office that performed vendor identification, quality control, production monitoring, price review, compliance checks and procurement coordination was held to do more than mere purchase activity. On that basis, its Indian operations were treated as creating a business connection, and income attributable to those operations was regarded as accruing or arising in India. The purchase-only statutory exclusion did not apply because the activities were not confined to buying goods for export. The office was also treated as a permanent establishment under the treaty, since it was a fixed place through which business was carried on and was not limited to preparatory, auxiliary, or information-collection functions; the attributable profits were therefore taxable in India. Case-Laws Income Tax Mon, 08 Aug 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=204939