https://www.taxtmi.com/caselaws?id=781005 A liaison office that only communicated with Indian entities, gathered and transmitted information, and had no authority to conclude contracts or undertake commercial activity was held to fall within preparatory or auxiliary functions under Article 5 of the India-Netherlands DTAA. On those facts, the office was not a permanent establishment in India, and the consequential attribution of profits could not be sustained. The addition made on the basis of PE and profit attribution was deleted. en-us Tue, 04 Nov 2025 00:00:00 +0530 Fri, 07 Nov 2025 13:01:02 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=781005 A liaison office that only communicated with Indian entities, gathered and transmitted information, and had no authority to conclude contracts or undertake commercial activity was held to fall within preparatory or auxiliary functions under Article 5 of the India-Netherlands DTAA. On those facts, the office was not a permanent establishment in India, and the consequential attribution of profits could not be sustained. The addition made on the basis of PE and profit attribution was deleted. Case-Laws Income Tax Tue, 04 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=781005