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Mere back-end operations outfit is held to be excluded from the term “permanent establishment” and classified as one for the supply of information and not chargeable to tax vide (2023] 21 ITR-OL 369 (Bom).

In this case from the scrutiny of documents found during survey there was no any document suggesting that substantial business had been done from the liaison office of Mauritius entity. 

In this case the revenue failed to establish that any substantial business has been done from the Mumbai office of Mauritian entity. 

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