https://www.taxtmi.com/caselaws?id=205975 Installation activities involving ground preparation, crane movement, load testing, holding equipment after erection, and setting, fitting, placing and positioning fabricated equipment at site were treated as installation or assembly projects, not supervisory services or services under the residuary provision. The resulting income was characterised as business profits under Article 7.1 of the Singapore DTAA and was taxable in India only if a permanent establishment existed. The four projects were independent, with no interconnection, interdependence or cohesiveness, so their periods could not be aggregated for the 183-day test under Article 5.3. A wholly owned subsidiary and the reference to a contact person were insufficient to create a permanent establishment; the income was therefore not taxable in India. en-us Mon, 19 Sep 2011 00:00:00 +0530 Mon, 07 Nov 2011 15:27:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=205975 Installation activities involving ground preparation, crane movement, load testing, holding equipment after erection, and setting, fitting, placing and positioning fabricated equipment at site were treated as installation or assembly projects, not supervisory services or services under the residuary provision. The resulting income was characterised as business profits under Article 7.1 of the Singapore DTAA and was taxable in India only if a permanent establishment existed. The four projects were independent, with no interconnection, interdependence or cohesiveness, so their periods could not be aggregated for the 183-day test under Article 5.3. A wholly owned subsidiary and the reference to a contact person were insufficient to create a permanent establishment; the income was therefore not taxable in India. Case-Laws Income Tax Mon, 19 Sep 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=205975