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    <description>A not-for-profit association&#039;s proposed liaison office in India was held not liable to tax under the Income-tax Act, 1961 or the India-Belgium DTAA because its activities were confined to promoting awareness and facilitating collective objects, not carrying on business for profit. The ruling applied mutuality: no special or selective services were rendered to particular members, and the existence of a permanent establishment was negatived once business activity was absent. Membership fees and member contributions were also held non-taxable, as they were received for common objects, any surplus was incidental and reinvested for the same purposes, and occasional conference-related receipts did not change their character.</description>
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