https://www.taxtmi.com/caselaws?id=253191 A liaison office was treated as a permanent establishment in India because its activities went beyond preparatory or auxiliary functions and extended to product explanation, commercial coordination, brand promotion, and market development. The treaty exclusion for preparatory or auxiliary activities therefore did not apply. On attribution, the taxing authority was required to determine only the profits actually attributable to the permanent establishment; a mere deduction of expenses from receipts was insufficient. The attribution issue was remitted for fresh determination, while the permanent establishment finding was sustained. en-us Tue, 11 Nov 2014 00:00:00 +0530 Mon, 09 Feb 2015 17:08:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=253191 A liaison office was treated as a permanent establishment in India because its activities went beyond preparatory or auxiliary functions and extended to product explanation, commercial coordination, brand promotion, and market development. The treaty exclusion for preparatory or auxiliary activities therefore did not apply. On attribution, the taxing authority was required to determine only the profits actually attributable to the permanent establishment; a mere deduction of expenses from receipts was insufficient. The attribution issue was remitted for fresh determination, while the permanent establishment finding was sustained. Case-Laws Income Tax Tue, 11 Nov 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=253191