https://www.taxtmi.com/caselaws?id=389497 A liaison office was treated as a Permanent Establishment on the Tribunal's factual findings, and the Court found no material change in the relevant year to justify interference. The later amendment to the second Explanation to section 9(1) did not unsettle that determination because the PE finding was made independently on evidence and the existing legal position. The plea of double taxation and prior attribution in the hands of the Indian entity was also rejected as factual and unsupported by any substantial question of law. The Tribunal's decision was therefore left undisturbed. en-us Mon, 02 Dec 2019 00:00:00 +0530 Mon, 09 Dec 2019 14:57:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=389497 A liaison office was treated as a Permanent Establishment on the Tribunal's factual findings, and the Court found no material change in the relevant year to justify interference. The later amendment to the second Explanation to section 9(1) did not unsettle that determination because the PE finding was made independently on evidence and the existing legal position. The plea of double taxation and prior attribution in the hands of the Indian entity was also rejected as factual and unsupported by any substantial question of law. The Tribunal's decision was therefore left undisturbed. Case-Laws Income Tax Mon, 02 Dec 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=389497