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Liaison Office for Export Purchases Not a Permanent Establishment Under DTAA Article 5; Income Not Taxable in India.
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....Income received or deemed to be received in India - liaison office is established only for the purpose of carrying on business of purchasing goods for the purpose of export and all that activity also falls within the meaning of the words "collecting information" for the enterprise - liaison office would not qualify to be a permanent establishment in terms of Article 5 of the DTAA - HC....