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Liaison Office involved in ascertaining customer requirement and obtaining purchase orders to be held PE

February 3, 2020[2020] 113 327 (Delhi - Trib.)/[2020] 180 ITD 861 (Delhi - Trib.)

INTERNATIONAL TAXATION: Where assessee, a Singapore based company, opened a Liaison Office (LO) in India, in view of fact that LO was not only involved in preparatory and auxiliary activities but also actively involved in ascertaining customer requirements, price negotiations obtaining of purchase orders, etc., it could be concluded that said LO Constituted assessee's PE in India in terms of articles 5 of India-Singapore DTAA

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