https://www.taxtmi.com/caselaws?id=780260 A Mumbai office that performs liaison functions and does not carry on core income-generating activities is treated as a liaison office, not a permanent establishment, so treaty attribution rules do not create Indian tax nexus. On that basis, receipts from offshore supply under divisible contracts were not taxable in India because they lacked connection with any Indian permanent establishment. Interest on delayed payment from the associated enterprise was characterised as debt-claim income under the treaty, and where no permanent establishment existed in India, the treaty's beneficial rate applied instead of the higher domestic rate. en-us Wed, 15 Oct 2025 00:00:00 +0530 Mon, 27 Oct 2025 09:17:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=780260 A Mumbai office that performs liaison functions and does not carry on core income-generating activities is treated as a liaison office, not a permanent establishment, so treaty attribution rules do not create Indian tax nexus. On that basis, receipts from offshore supply under divisible contracts were not taxable in India because they lacked connection with any Indian permanent establishment. Interest on delayed payment from the associated enterprise was characterised as debt-claim income under the treaty, and where no permanent establishment existed in India, the treaty's beneficial rate applied instead of the higher domestic rate. Case-Laws Income Tax Wed, 15 Oct 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=780260