https://www.taxtmi.com/caselaws?id=271342 Delhi HC examined treaty permanent establishment tests and held that the Indian Project Office was only performing preparatory or auxiliary liaison functions, so it was excluded from PE status. It further found that the installation or construction activity did not continue in India for the treaty-prescribed period after excluding the gap when access to the site was unavailable, and the Indian agent was an independent business entity without authority to conclude contracts, so no dependent agent PE arose. As no PE existed, no contract profits could be attributed to India. The assessee's alternative computation method under Article 7(6) and Section 44BB was not accepted. en-us Fri, 29 Jan 2016 00:00:00 +0530 Tue, 24 May 2016 17:44:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=271342 Delhi HC examined treaty permanent establishment tests and held that the Indian Project Office was only performing preparatory or auxiliary liaison functions, so it was excluded from PE status. It further found that the installation or construction activity did not continue in India for the treaty-prescribed period after excluding the gap when access to the site was unavailable, and the Indian agent was an independent business entity without authority to conclude contracts, so no dependent agent PE arose. As no PE existed, no contract profits could be attributed to India. The assessee's alternative computation method under Article 7(6) and Section 44BB was not accepted. Case-Laws Income Tax Fri, 29 Jan 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=271342