https://www.taxtmi.com/caselaws?id=206664 The Court held that the appellant did not have a permanent establishment in India for the assessment year 1994-95, as per the treaty provisions. Consequently, the appellant's revenue was not taxable in India. The Court emphasized that the specific treaty provision regarding project duration prevailed over the general provision, leading to the dismissal of the revenue's appeal and confirming the non-taxability of the appellant's income in India. en-us Fri, 14 Oct 2011 00:00:00 +0530 Thu, 10 Nov 2011 19:30:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=206664 The Court held that the appellant did not have a permanent establishment in India for the assessment year 1994-95, as per the treaty provisions. Consequently, the appellant's revenue was not taxable in India. The Court emphasized that the specific treaty provision regarding project duration prevailed over the general provision, leading to the dismissal of the revenue's appeal and confirming the non-taxability of the appellant's income in India. Case-Laws Income Tax Fri, 14 Oct 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=206664