https://www.taxtmi.com/caselaws?id=179255 Liaison offices maintained solely for collecting information, forwarding market inputs and arranging meetings were treated as preparatory or auxiliary activities under Article 5(6)(e) of the India-Japan tax treaty, so they did not create a permanent establishment in India. The record did not show that the offices independently concluded contracts, transacted business, or had authority to bind the head office. Survey material relied on by the Revenue was insufficient to displace the consistent view taken in earlier years, especially where much of it related to periods outside the assessment year. The material also did not establish breach of RBI conditions affecting the treaty analysis, so no income was taxable in India on that basis. en-us Fri, 08 Feb 2008 00:00:00 +0530 Wed, 24 Feb 2016 10:58:21 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=179255 Liaison offices maintained solely for collecting information, forwarding market inputs and arranging meetings were treated as preparatory or auxiliary activities under Article 5(6)(e) of the India-Japan tax treaty, so they did not create a permanent establishment in India. The record did not show that the offices independently concluded contracts, transacted business, or had authority to bind the head office. Survey material relied on by the Revenue was insufficient to displace the consistent view taken in earlier years, especially where much of it related to periods outside the assessment year. The material also did not establish breach of RBI conditions affecting the treaty analysis, so no income was taxable in India on that basis. Case-Laws Income Tax Fri, 08 Feb 2008 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=179255