https://www.taxtmi.com/highlights?id=68918 Income deemed to accrue or arise in India - Liaison Office (LO) as a Service PE or Dependent Agency Permanent Establishment (DAPE) - LO did not carry any activity, beyond that permitted by the RBI. - The activities/operations of the assessee in connection with the contracts are carried from outside India. - LO of subsidiary of assessee does not constitute a PE in the case of assessee, hence, addition on this ground made by AO is directed to be deleted. - AT en-us Sat, 25 Mar 2023 13:56:30 +0530 Sat, 25 Mar 2023 13:56:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=68918 Income deemed to accrue or arise in India - Liaison Office (LO) as a Service PE or Dependent Agency Permanent Establishment (DAPE) - LO did not carry any activity, beyond that permitted by the RBI. - The activities/operations of the assessee in connection with the contracts are carried from outside India. - LO of subsidiary of assessee does not constitute a PE in the case of assessee, hence, addition on this ground made by AO is directed to be deleted. - AT Highlights Income Tax Sat, 25 Mar 2023 13:56:30 +0530 https://www.taxtmi.com/highlights?id=68918