A 17 September 2019 decision of the Delhi Income Tax Appellate Tribunal has been published concerning the treatment of a liaison office as a permanent establishment. The case involved Hitachi High Technologies Singapore Pte Ltd (HHT Singapore), which established a liaison office (LO) in India for rendering preparatory and auxiliary services, including market research and liaison activities. In 2008, a survey operation was carried out by the tax authority, which resulted in reassessment proceedings. During the proceedings, the assessment officer alleged that the LO was engaged in executing/negotiating contracts for the appellant in India and was not merely undertaking preparatory...