https://www.taxtmi.com/caselaws?id=60451 Liaison offices in India that were approved only for collecting and transmitting information, funded entirely by foreign remittances, and without authority to conclude contracts or carry on trading activity fell within the treaty exclusion for preparatory or auxiliary functions. On those facts, they did not constitute a permanent establishment under the India-Japan tax treaty, and income could not be attributed to them under the domestic charging provisions where inconsistent with the treaty. en-us Tue, 30 Oct 2007 00:00:00 +0530 Sun, 06 Feb 2011 03:13:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=60451 Liaison offices in India that were approved only for collecting and transmitting information, funded entirely by foreign remittances, and without authority to conclude contracts or carry on trading activity fell within the treaty exclusion for preparatory or auxiliary functions. On those facts, they did not constitute a permanent establishment under the India-Japan tax treaty, and income could not be attributed to them under the domestic charging provisions where inconsistent with the treaty. Case-Laws Income Tax Tue, 30 Oct 2007 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=60451