https://www.taxtmi.com/caselaws?id=211311 A prima facie case for stay of recovery was shown where the dispute concerned whether liaison office activities crossed preparatory or auxiliary functions and created a permanent establishment in India. The Tribunal noted that the existence of a permanent establishment was debatable on the material placed, and that the Assessing Officer had treated the evidence as sketchy while still making attribution of profits. It also noted that profit attribution had been estimated by applying a gross profit rate and Rule 10(iii), without regard to the assessee's disclosed global margin. Recovery was stayed subject to instalments and the usual stay conditions. en-us Fri, 23 Dec 2011 00:00:00 +0530 Tue, 13 Mar 2012 11:25:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=211311 A prima facie case for stay of recovery was shown where the dispute concerned whether liaison office activities crossed preparatory or auxiliary functions and created a permanent establishment in India. The Tribunal noted that the existence of a permanent establishment was debatable on the material placed, and that the Assessing Officer had treated the evidence as sketchy while still making attribution of profits. It also noted that profit attribution had been estimated by applying a gross profit rate and Rule 10(iii), without regard to the assessee's disclosed global margin. Recovery was stayed subject to instalments and the usual stay conditions. Case-Laws Income Tax Fri, 23 Dec 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=211311