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2012 Supreme(SC) 501

A.K.PATNAIK, SWATANTER KUMAR
COLUMBIA SPORTSWEAR COMPANY – Appellant
Versus
DIRECTOR OF INCOME TAX, BANGALORE – Respondent


ORDER


A. K. Patnaik, J.-Special Leave Petition (C) No. 31543 of 2011:


1. This is a petition under Article 136 of the Constitution of India seeking special leave to appeal against the order dated 08.08.2011 of the Authority for Advance Rulings (Income Tax) constituted under Chapter XIX-B of the Income Tax Act, 1961 (for short ‘the Act’) in A.A.R. No.862 of 2009.


2. The petitioner is a company incorporated in the United States of America (for short ‘the USA’) and is engaged in the business of designing, developing, marketing and distributing outdoor apparel. For making purchases for its business, the petitioner established a liaison office in Chennai with the permission of the Reserve Bank of India (for short ‘the RBI’) in 1995. The RBI granted the permission in its letter dated 01.03.1995 subject to the conditions stipulated therein. The permission letter dated 01.03.1995 of the RBI stated that the liaison office of the petitioner was for the purpose of undertaking purely liaison activities viz. to inspect the quality, to ensure shipments and to act as a communication channel between head office and parties in India and except such liaison work, the liaison office will not underta






























































































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