https://www.taxtmi.com/highlights?id=65597 Income deemed or accrue or arise in India - liaison office - Permanent Establishment (PE) - Revenue though vehemently submitted that liaison office was negotiating price and doing sales activity in India, however, has not brought any sales agreement in support of the claim. It is highly doubtful that sales transaction of such a large scale can be conducted internationally without any written agreement. - the liaison office in Mumbai does not constitute PE of the assessee in India under the provisions of DTAA. - AT en-us Mon, 12 Sep 2022 13:55:23 +0530 Mon, 12 Sep 2022 13:55:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=65597 Income deemed or accrue or arise in India - liaison office - Permanent Establishment (PE) - Revenue though vehemently submitted that liaison office was negotiating price and doing sales activity in India, however, has not brought any sales agreement in support of the claim. It is highly doubtful that sales transaction of such a large scale can be conducted internationally without any written agreement. - the liaison office in Mumbai does not constitute PE of the assessee in India under the provisions of DTAA. - AT Highlights Income Tax Mon, 12 Sep 2022 13:55:23 +0530 https://www.taxtmi.com/highlights?id=65597