https://www.taxtmi.com/caselaws?id=216601 A liaison office carrying on only preparatory and auxiliary activities was not treated as a business connection or permanent establishment in India. Offshore supply of hardware and embedded software was held to be a completed sale outside India, with title and risk passing abroad; the software was a copyrighted article rather than a transfer of copyright rights, so the receipts were not taxable as royalty and interest under section 234B was not leviable on the non-resident. Attribution of profits to the alleged permanent establishment and any notional interest on delayed consideration or vendor financing required fresh factual reconsideration and was remitted. en-us Fri, 07 Sep 2012 00:00:00 +0530 Mon, 16 Feb 2026 11:52:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=216601 A liaison office carrying on only preparatory and auxiliary activities was not treated as a business connection or permanent establishment in India. Offshore supply of hardware and embedded software was held to be a completed sale outside India, with title and risk passing abroad; the software was a copyrighted article rather than a transfer of copyright rights, so the receipts were not taxable as royalty and interest under section 234B was not leviable on the non-resident. Attribution of profits to the alleged permanent establishment and any notional interest on delayed consideration or vendor financing required fresh factual reconsideration and was remitted. Case-Laws Income Tax Fri, 07 Sep 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=216601