https://www.taxtmi.com/caselaws?id=435702 A liaison office in India that is limited to communication and coordination within RBI approval, and does not negotiate or conclude contracts or carry on core business operations, is treated as only preparatory or auxiliary activity and not a permanent establishment under Article 5 of the India-Switzerland DTAA. Where the Indian office has no authority or infrastructure to conduct business, service PE or agency PE cannot be established, and profits cannot be attributed to India on an estimated basis. On those facts, the addition made on the footing of an alleged PE was deleted. en-us Fri, 25 Nov 2022 00:00:00 +0530 Thu, 23 Mar 2023 14:43:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=435702 A liaison office in India that is limited to communication and coordination within RBI approval, and does not negotiate or conclude contracts or carry on core business operations, is treated as only preparatory or auxiliary activity and not a permanent establishment under Article 5 of the India-Switzerland DTAA. Where the Indian office has no authority or infrastructure to conduct business, service PE or agency PE cannot be established, and profits cannot be attributed to India on an estimated basis. On those facts, the addition made on the footing of an alleged PE was deleted. Case-Laws Income Tax Fri, 25 Nov 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=435702