Income can’t be attributed to LO in India if its operations are confined to assisting manufacturers

IT/ILT : Where assessee-foreign company's presence in India is limited to its liaison office which assist Indian manufacturers to manufacture goods according to specification for export to buyers in other countries (which are subsidiaries of assessee), it can be said that activities of non-resident assessee are confined in India to purchase of goods for export and hence income derived therefrom shall not be deemed to accrue or arise in India and shall be entitled to exemption under Explanation 1