https://www.taxtmi.com/caselaws?id=32091 Income from India-related remittance operations was treated as deemed to accrue or arise in India where the liaison offices did more than clerical support and performed an essential part of the second remittance mode by downloading beneficiary data, printing instruments and dispatching them in India. That business activity created a real and intimate connection with the Indian operations, making the income attributable to those activities taxable in India under section 9. For treaty purposes, the liaison offices were not confined to preparatory or auxiliary functions because they formed a significant part of the core business function, so they constituted a permanent establishment for the second remittance mode. en-us Wed, 26 May 2004 00:00:00 +0530 Thu, 15 Mar 2012 16:04:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=32091 Income from India-related remittance operations was treated as deemed to accrue or arise in India where the liaison offices did more than clerical support and performed an essential part of the second remittance mode by downloading beneficiary data, printing instruments and dispatching them in India. That business activity created a real and intimate connection with the Indian operations, making the income attributable to those activities taxable in India under section 9. For treaty purposes, the liaison offices were not confined to preparatory or auxiliary functions because they formed a significant part of the core business function, so they constituted a permanent establishment for the second remittance mode. Case-Laws Income Tax Wed, 26 May 2004 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=32091