https://www.taxtmi.com/caselaws?id=338018 A liaison office does not constitute a permanent establishment where, for the relevant year, its activities are limited to communication, coordination, market-information gathering and other preparatory or auxiliary support, without independent business decisions or profit-centre functions. On that basis, no income attribution could be sustained through an ad hoc Rule 10 turnover or gross-profit estimation; certified turnover figures were accepted and the revenue's formulaic adjustment failed. Interest under section 234B was also not leviable on the non-resident where tax was deductible at source but the payer failed to deduct it. en-us Thu, 12 Jan 2017 00:00:00 +0530 Sun, 22 Jan 2017 09:20:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=338018 A liaison office does not constitute a permanent establishment where, for the relevant year, its activities are limited to communication, coordination, market-information gathering and other preparatory or auxiliary support, without independent business decisions or profit-centre functions. On that basis, no income attribution could be sustained through an ad hoc Rule 10 turnover or gross-profit estimation; certified turnover figures were accepted and the revenue's formulaic adjustment failed. Interest under section 234B was also not leviable on the non-resident where tax was deductible at source but the payer failed to deduct it. Case-Laws Income Tax Thu, 12 Jan 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=338018