The assessee company, incorporated under laws of Singapore  is engaged  in  trading operations of various products equipment’s in India. Assessee established a liaison office in India for preparatory and auxiliary  services, including market research and liaison activities. AO held that liaison office  Involved in preparatory and auxiliary activities but also involved in ascertaining customer requirements, price negotiations obtaining of purchase orders etc. therefore  constituted PE in India in terms of Art 5 of India-Singapore DTAA. On  appeal the Tribunal held that from the records that employees of assessee liaison office were engaged in marketing, sales promotion and market research activities which were sine qua for trading business. Tribunal also held that  liaison office is  also involved in ascertaining customer requirements, price negotiations obtaining of purchase orders etc. Accordingly the Tribunal affirmed the order of AO and held that liaison office constituted PE in India and profit attribution has to be  taxable in India. (AY. 2002-03 to 2007-08)