https://www.taxtmi.com/caselaws?id=216233 Under the India-UAE tax treaty, the construction-project duration test applies separately to each site or project unless the facts show a connected, interdependent commercial whole; mere common client or geographic proximity is insufficient, so the two contracts were not aggregated and no permanent establishment arose in India. Barge hire receipts were taxable in India because that issue was accepted as covered against the assessee. Receipts for services rendered beyond India's continental shelf and exclusive economic zone were not taxable in India because the Act's extension applies only to the notified area, and separately identifiable offshore receipts outside that area fall outside Indian tax. en-us Mon, 05 Apr 2010 00:00:00 +0530 Mon, 21 Jan 2013 11:30:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=216233 Under the India-UAE tax treaty, the construction-project duration test applies separately to each site or project unless the facts show a connected, interdependent commercial whole; mere common client or geographic proximity is insufficient, so the two contracts were not aggregated and no permanent establishment arose in India. Barge hire receipts were taxable in India because that issue was accepted as covered against the assessee. Receipts for services rendered beyond India's continental shelf and exclusive economic zone were not taxable in India because the Act's extension applies only to the notified area, and separately identifiable offshore receipts outside that area fall outside Indian tax. Case-Laws Income Tax Mon, 05 Apr 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=216233