https://www.taxtmi.com/caselaws?id=205814 A liaison office that identifies customers, negotiates prices within head-office limits, secures purchase orders and follows up payments is not confined to preparatory or auxiliary functions. Those activities create a business connection in India under section 9(1)(i), so income reasonably attributable to the Indian operations is taxable. On the treaty analysis, an office through which the enterprise carries on business, other than for merely auxiliary work, is a permanent establishment under Article 5 of the India-South Korea DTAA. Profits attributable to that permanent establishment are taxable in India under Article 7. en-us Thu, 30 Apr 2009 00:00:00 +0530 Thu, 06 Jun 2013 10:12:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=205814 A liaison office that identifies customers, negotiates prices within head-office limits, secures purchase orders and follows up payments is not confined to preparatory or auxiliary functions. Those activities create a business connection in India under section 9(1)(i), so income reasonably attributable to the Indian operations is taxable. On the treaty analysis, an office through which the enterprise carries on business, other than for merely auxiliary work, is a permanent establishment under Article 5 of the India-South Korea DTAA. Profits attributable to that permanent establishment are taxable in India under Article 7. Case-Laws Income Tax Thu, 30 Apr 2009 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=205814