https://www.taxtmi.com/caselaws?id=238949 Treaty permanent establishment under Article 5(2)(i) of the India-Mauritius DTAA had to be verified by first establishing the actual period of the assessee's presence in India, because the project duration and taxability could not be conclusively determined on the existing record. The matter was therefore sent back for de novo examination by the Assessing Officer. The related addition concerning an alleged refund was also remanded for fresh verification, with the assessee to be heard again. The document does not record a final merits determination; it describes a restoration of the substantive issues to the assessment stage. en-us Fri, 31 Aug 2012 00:00:00 +0530 Thu, 24 Oct 2013 20:19:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=238949 Treaty permanent establishment under Article 5(2)(i) of the India-Mauritius DTAA had to be verified by first establishing the actual period of the assessee's presence in India, because the project duration and taxability could not be conclusively determined on the existing record. The matter was therefore sent back for de novo examination by the Assessing Officer. The related addition concerning an alleged refund was also remanded for fresh verification, with the assessee to be heard again. The document does not record a final merits determination; it describes a restoration of the substantive issues to the assessment stage. Case-Laws Income Tax Fri, 31 Aug 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=238949