Liaison office not in core business activity, not constitute PE

Brief of the Case ITAT Delhi held In the case of Kawasaki Heavy Industries Ltd. vs. ACIT that a plain reading of the power of attorney, makes it clears that the powers given therein are liaison office specific. The AO’s conclusion that the power of attorney granted unfettered powers to its liaison office’s employee, to do all or any acts for and on behalf of the assessee, is incorrect. Also, it is beyond the jurisdiction of the AO to adjudicate and conclude that the assessee has filed false declarations before the RBI. At best, he can bring his findings to the notice of the RBI which may c...