Liaison Office Not a PE, Offshore Revenues & Interest Not Taxable in India: ITAT Delhi

DCIT Vs Hyundai Heavy Industries Ltd (ITAT Delhi) Liaison Office Not a PE, Offshore Revenues & Interest Not Taxable in India – Revenue’s Appeals Against Hyundai Dismissed Completely These three Revenue appeals arise from reassessment orders passed after remand by ITAT & subsequent relief granted by CIT(A). The core issues relate to (i) Whether the Assessee’s Mumbai Liaison Office constitutes a Permanent Establishment (PE) in India; (ii) Taxability of offshore revenues / Fees for Technical Services (FTS); (iii) Taxability of interest from Associated Enterprises (AE) under DTAA. Li...