Liaison Office having active role treated as Permanent Establishment in terms of Article 5(2) of India-Germany DTAA

Springer Verlag GmbH Vs DCIT (ITAT Delhi) ITAT Delhi held that Liaison Office playing an active role with regard to printing of books treatable as Permanent Establishment in terms of Article 5(2) of India-Germany Double Taxation Avoidance Agreement (DTAA). Facts- The assessee is a non-resident corporate entity incorporated in Germany and a tax resident of Germany. The assessee is a pioneer in publishing scientific, technical, medical books and journals. The assessee got an approval from Reserve Bank of India (RBI) on 08.12.1997, to open a Liaison Office ( LO ) in India. A survey u/s. 133A of t...