https://www.taxtmi.com/caselaws?id=356731 A liaison office will not constitute a permanent establishment under the India-Japan DTAA where its activities are confined to information gathering, liaison work and follow-up functions, rather than concluding contracts or independently carrying on trading activity in India. The Court found no perversity in the Tribunal's factual findings and held that the Revenue's remand material and survey evidence did not prove business operations beyond preparatory or auxiliary functions. It further upheld the view that the Revenue had not established a basis to displace the assessee's treaty protection, so the income was not taxable in India on that footing. en-us Thu, 12 Oct 2017 00:00:00 +0530 Tue, 18 Sep 2018 17:38:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=356731 A liaison office will not constitute a permanent establishment under the India-Japan DTAA where its activities are confined to information gathering, liaison work and follow-up functions, rather than concluding contracts or independently carrying on trading activity in India. The Court found no perversity in the Tribunal's factual findings and held that the Revenue's remand material and survey evidence did not prove business operations beyond preparatory or auxiliary functions. It further upheld the view that the Revenue had not established a basis to displace the assessee's treaty protection, so the income was not taxable in India on that footing. Case-Laws Income Tax Thu, 12 Oct 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=356731