Liaison office in India doesn’t constitute PE in India

Nagase And Company Ltd. Vs ADIT (ITAT Mumbai) ITAT Mumbai held that liaison office in India doesn’t constitute permanent establishment (PE) of the assessee in India under the provisions of DTAA. Facts- The assessee is a public company incorporated in Japan, which is engaged in the business of import/export as well as domestic sales of dyestuffs, chemicals, plastic, machinery, electronic materials, cosmetics, health foods and medical equipment. In 1974, the assessee opened a liaison office in Mumbai after obtaining necessary approvals from the Reserve Bank of India (RBI). In terms of the perm...