https://www.taxtmi.com/caselaws?id=272000 A liaison office does not constitute a fixed place permanent establishment in India unless the Revenue proves with cogent material that it performs core business functions, concludes contracts, or otherwise carries on income-earning activity in India; where the record shows only liaison functions and head office handling of orders and contract execution, permanent establishment is not established. Once no permanent establishment exists, attribution of fees for technical services to that establishment cannot stand and the matter may require fresh examination of treaty-based taxation and applicable rates on the correct legal footing. Interest under section 234B is not leviable in a non-resident taxation context where tax is deductible at source. en-us Thu, 11 Feb 2016 00:00:00 +0530 Sat, 30 Apr 2016 12:18:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=272000 A liaison office does not constitute a fixed place permanent establishment in India unless the Revenue proves with cogent material that it performs core business functions, concludes contracts, or otherwise carries on income-earning activity in India; where the record shows only liaison functions and head office handling of orders and contract execution, permanent establishment is not established. Once no permanent establishment exists, attribution of fees for technical services to that establishment cannot stand and the matter may require fresh examination of treaty-based taxation and applicable rates on the correct legal footing. Interest under section 234B is not leviable in a non-resident taxation context where tax is deductible at source. Case-Laws Income Tax Thu, 11 Feb 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=272000