https://www.taxtmi.com/caselaws?id=266493 A non-resident liaison office engaged only in purchase coordination, information collection and related support for export procurement falls within the statutory and treaty exceptions for purchasing activity. Under Section 9(1)(i) read with Explanation 1(b), no income is deemed to accrue in India where Indian operations are confined to purchase of goods for export. Article 5(3)(d) of the India-USA DTAA likewise excludes a fixed place maintained solely for purchasing goods or collecting information from permanent establishment status, and Article 7 taxes profits only to the extent attributable to a permanent establishment. On this framework, purchase-support functions are treated as non-taxable purchase operations rather than a separate commercial activity in India. en-us Thu, 03 Sep 2015 00:00:00 +0530 Tue, 20 Oct 2015 10:35:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=266493 A non-resident liaison office engaged only in purchase coordination, information collection and related support for export procurement falls within the statutory and treaty exceptions for purchasing activity. Under Section 9(1)(i) read with Explanation 1(b), no income is deemed to accrue in India where Indian operations are confined to purchase of goods for export. Article 5(3)(d) of the India-USA DTAA likewise excludes a fixed place maintained solely for purchasing goods or collecting information from permanent establishment status, and Article 7 taxes profits only to the extent attributable to a permanent establishment. On this framework, purchase-support functions are treated as non-taxable purchase operations rather than a separate commercial activity in India. Case-Laws Income Tax Thu, 03 Sep 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=266493