IT/ILT : Liaison Office of foreign MNC established in India for sourcing goods for exports to its overseas customers as per their requirements will not be treated as PE under the DTAA merely because it engages in activities necessary for purchase such as identifying a competent manufacturer, negotiating a competitive price, helping in choosing material to be used, ensuring compliance with quality of the material and getting material tested to ensure quality. Nor will the LO lose tax exemption
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