https://www.taxtmi.com/caselaws?id=307684 The Court dismissed the appeal as it found no substantial question of law for consideration. It was established in a previous case that the Liaison Office did not constitute a Permanent Establishment (PE) liable to tax in India. The Court also noted that MIPL was not considered a Dependent Agency PE, as it was not performing additional functions. Therefore, the appeal was dismissed based on the previous determinations and factual findings regarding the PE status and income attributability in India. en-us Wed, 09 Nov 2022 00:00:00 +0530 Fri, 28 Apr 2023 21:22:02 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=307684 The Court dismissed the appeal as it found no substantial question of law for consideration. It was established in a previous case that the Liaison Office did not constitute a Permanent Establishment (PE) liable to tax in India. The Court also noted that MIPL was not considered a Dependent Agency PE, as it was not performing additional functions. Therefore, the appeal was dismissed based on the previous determinations and factual findings regarding the PE status and income attributability in India. Case-Laws Income Tax Wed, 09 Nov 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=307684