Where liaison office of assessee merely co-ordinated its purchases in India, it could not be regarded as assessee’s PE in India

IN THE ITAT MUMBAI BENCH ‘L’ Deputy Director of Income-tax (International Taxation) versus M. Fabricant & Sons Inc. IT APPEAL NOS. 2760 (MUM.) OF 2009 & 7514 (MUM.) OF 2010 [ASSESSMENT YEARs 2006-07 & 2007-08] JULY 31, 2012 ORDER 1. The appeal in ITA No. 2760/Mum/2009 preferred by the Revenue is directed against the order dtd. 31-1-2007 passed by the ld. CIT(A) for A.Y. 2006-07 and the appeal in ITA No. 7514/Mum/2010 preferred by the assessee for the A.Y. 2007-08 is directed against the order dtd. 8-9-2010 passed by the A.O. in pursuance to the directi...