https://www.taxtmi.com/caselaws?id=207032 A construction or assembly project under Article 5(2)(i) of the India-Mauritius DTAA is subject to the specific nine-month threshold, and that temporal condition governs pipeline-laying work treated as assembly rather than a mere service activity. The general fixed-place rule in Article 5(1) does not displace the specific treaty rule for such projects, so a permanent establishment arises only if the project continues for more than nine months. Because the exact project duration was not examined below, that factual issue required verification and the matter was remitted for limited determination. en-us Fri, 16 Sep 2011 00:00:00 +0530 Fri, 24 May 2013 12:40:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=207032 A construction or assembly project under Article 5(2)(i) of the India-Mauritius DTAA is subject to the specific nine-month threshold, and that temporal condition governs pipeline-laying work treated as assembly rather than a mere service activity. The general fixed-place rule in Article 5(1) does not displace the specific treaty rule for such projects, so a permanent establishment arises only if the project continues for more than nine months. Because the exact project duration was not examined below, that factual issue required verification and the matter was remitted for limited determination. Case-Laws Income Tax Fri, 16 Sep 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=207032