https://www.taxtmi.com/caselaws?id=338287 The High Court held that the non-resident company's liaison office in India did not constitute a permanent establishment for tax liability purposes. The Court determined that the activities of the liaison office were preparatory and auxiliary in nature, supporting the main business functions of the company without establishing a deep and intimate commercial connection. Additionally, the Court ruled that the income from imports in India by the non-resident company was not taxable under the Indo-Japan Double Taxation Avoidance Agreement, as the functions performed by the office were deemed auxiliary and did not amount to a business connection under the agreement. en-us Wed, 17 Aug 2016 00:00:00 +0530 Tue, 31 Jan 2017 06:42:14 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=338287 The High Court held that the non-resident company's liaison office in India did not constitute a permanent establishment for tax liability purposes. The Court determined that the activities of the liaison office were preparatory and auxiliary in nature, supporting the main business functions of the company without establishing a deep and intimate commercial connection. Additionally, the Court ruled that the income from imports in India by the non-resident company was not taxable under the Indo-Japan Double Taxation Avoidance Agreement, as the functions performed by the office were deemed auxiliary and did not amount to a business connection under the agreement. Case-Laws Income Tax Wed, 17 Aug 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=338287