https://www.taxtmi.com/caselaws?id=386042 A liaison office performing marketing, sales promotion, price negotiation, order follow-up, delivery and collection functions may constitute a permanent establishment under the India-Singapore treaty because those activities exceed preparatory or auxiliary work. Profits attributable to such a permanent establishment must reflect the functions performed, assets employed and risks assumed; attribution should be recomputed using TNMM after excluding unsuitable comparables. Fresh assessment following remand cannot place the assessee in a materially worse position than the original assessment. For a non-resident, interest for advance-tax default is not leviable to the extent payments are subject to tax deduction at source. en-us Tue, 17 Sep 2019 00:00:00 +0530 Fri, 20 Sep 2019 15:43:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=386042 A liaison office performing marketing, sales promotion, price negotiation, order follow-up, delivery and collection functions may constitute a permanent establishment under the India-Singapore treaty because those activities exceed preparatory or auxiliary work. Profits attributable to such a permanent establishment must reflect the functions performed, assets employed and risks assumed; attribution should be recomputed using TNMM after excluding unsuitable comparables. Fresh assessment following remand cannot place the assessee in a materially worse position than the original assessment. For a non-resident, interest for advance-tax default is not leviable to the extent payments are subject to tax deduction at source. Case-Laws Income Tax Tue, 17 Sep 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=386042