https://www.taxtmi.com/caselaws?id=211597 An Indian liaison office that, in substance, identifies customers, negotiates prices, procures and processes orders, follows up payments, and provides sales support is not confined to preparatory or auxiliary activity; it functions as a permanent establishment under Article 5 of the DTAA. The fact that purchase orders are formally placed on the head office and remittances are made there does not change the real character of the Indian activity. Profits attributable to that permanent establishment are taxable in India under Article 7. RBI permission restrictions did not alter the tax consequence because the actual conduct showed commercial activity in India. en-us Tue, 08 Feb 2011 00:00:00 +0530 Tue, 27 Mar 2012 07:52:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=211597 An Indian liaison office that, in substance, identifies customers, negotiates prices, procures and processes orders, follows up payments, and provides sales support is not confined to preparatory or auxiliary activity; it functions as a permanent establishment under Article 5 of the DTAA. The fact that purchase orders are formally placed on the head office and remittances are made there does not change the real character of the Indian activity. Profits attributable to that permanent establishment are taxable in India under Article 7. RBI permission restrictions did not alter the tax consequence because the actual conduct showed commercial activity in India. Case-Laws Income Tax Tue, 08 Feb 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=211597