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2011 (1) TMI 158 - AT - Income TaxAddition of income -circular no. 23 and 163 - M/s M Fabrikant and Sons Inc is a company based in USA and is in the business of sale of loose diamonds and diamond jewellery the India Liaison office (LO) has been opened in 1980 for purchase of finished loose diamonds from Indian Market - The AO issued a SCN to show why the Indian Liaison Office should not be treated as PE in India - It is a case of purchase of goods through LO and all the activities carried out by the LO are basic and preliminary requirement of the purchasing process/operation - the case is fully covered by the clause (b) of explanation (1) to section 9(1)(i) of the Act – Appeal of revenue are dismissed
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