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Tax on Income of Liaison offices carrying business of preparatory or auxiliary character
Case Law Details
- Case Name
- Union of India & Anr. Vs U.A.E. Exchange Centre (Supreme Court)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Courts
- Supreme Court of India
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Union of India & Anr. Vs U.A.E. Exchange Centre (Supreme Court)
Liaison offices carrying on business of preparatory or auxiliary character was neither liable to tax u/s 5, 9 of 1961 Act nor under Article 5, 7 of DTAA with UAE
Conclusion: Since the activities carried on by the liaison office of the non-resident in India was to only carry on such activity of a ‘preparatory or auxiliary’ character, therefore, the same was not a PE in terms of Article 5 of the DTAA and the deeming provisions in Sections 5 and 9 of the 1961 Act could have no bearing.
Held: Assessee ...
