The Liaison Office (LO) of non-resident taxpayer would qualify as business connection PE in India if the activities of the LO not confined to purchase of goods in India for the purpose of export

Columbia Sportswear Company Vs. DIT (International Taxation), Bangalore- (Advance Ruling Authority) – In addition to the activities relating to the purchase of goods, the Liaison Office was carrying out various activities such as ensuring the choice of quality material, occasional quality testing, conveying of requisite design, picking out competitive sellers, etc. Further, the Liaison Office facilitated the business of the applicant in Eygpt and Bangladesh. It will be unrealistic that all the activities other than the actual sale of the goods are not integral part of the business of the...