Liaison Office (LO) involved merely in purchasing activity is not a Permanent Establishment (PE)

Liaison Office (LO) involved merely in purchasing activity is not a Permanent Establishment (PE) ADIT (IT) Vs Fabrikant & Sons Ltd. (Appeal Nos. 4657 to 4660 and 3342) dated 28 January 2011 The facts and the issues were same for the relevant assessment years i.e.1999-2000 to 2002-03 and 2003-04. A tax survey was carried out in the financial year 2005-06 in the premises of the assessee. The following findings were recorded: • M Fabrikant and Sons Inc (F&S Inc) was a company based in USA and engaged in the business of sale of loose diamonds and diamond jewellery. • The India LO of th...