LO doing preparatory activities in India not constitute PE under Article 5 of India Switzerland DTAA

S.R. Technics Switzerland Limited Vs ACIT (International Taxation) (ITAT Mumbai)

The LO does not constitute a fixed place through which business of assessee is carried out in India. Employees of the LO do not negotiate, finalise or discuss the mechanics of contracts including pricing with the assessee’s customers. As such the employees of LO merely act as a communication link between the assessee and the airline companies. The LO did not carry any activity, beyond that permitted by the RBI. The activities carried by th

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