India-Japan DTAA: Liaison Office Not a Permanent Establishment Unless Activities Exceed Permitted Functions or Show Business Conduct.

DTAA between India and Japan - Whether Liasion Office constitutes its Permanent Establishment - LO cannot be taken to be a PE unless its activities exceed the permitted activities or the department lays hand on any concrete material or evidence to state that any substantive business activity has been carried on from this place. - AT .....

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