https://www.taxtmi.com/caselaws?id=304189 The Liaison Office did not constitute a permanent establishment in India under Article 5 of the India-Japan Tax Treaty because the impounded material did not show that it concluded contracts, carried on independent commercial activity, or functioned as a profit centre for the head office. Documents relating to performance reviews, an independent agent, staff attendance at a meeting, and correspondence on sales targets and demurrage were found insufficient, especially as they did not conclusively relate to the relevant assessment year. On that basis, no attribution of income to India was justified and the addition was deleted. en-us Fri, 22 Feb 2019 00:00:00 +0530 Tue, 13 Sep 2022 05:53:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=304189 The Liaison Office did not constitute a permanent establishment in India under Article 5 of the India-Japan Tax Treaty because the impounded material did not show that it concluded contracts, carried on independent commercial activity, or functioned as a profit centre for the head office. Documents relating to performance reviews, an independent agent, staff attendance at a meeting, and correspondence on sales targets and demurrage were found insufficient, especially as they did not conclusively relate to the relevant assessment year. On that basis, no attribution of income to India was justified and the addition was deleted. Case-Laws Income Tax Fri, 22 Feb 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=304189