Tax on Income of Liaison offices carrying business of preparatory or auxiliary character

Union of India & Anr. Vs U.A.E. Exchange Centre (Supreme Court) Liaison offices carrying on business of preparatory or auxiliary character was neither liable to tax u/s 5, 9 of 1961 Act nor under Article 5, 7 of DTAA with UAE Conclusion: Since the activities carried on by the liaison office of the non-resident in India was to only carry on such activity of a ‘preparatory or auxiliary’ character, therefore, the same was not a PE in terms of Article 5 of the DTAA and the deeming provisions in Sections 5 and 9 of the 1961 Act could have no bearing. Held: Assessee was a limited com...