https://www.taxtmi.com/caselaws?id=261152 A specific treaty rule for construction or installation projects governs subsea installation contracts under the India-Singapore DTAA, so Article 5(6) for services cannot override Article 5(3). The projects had to be tested separately on their own facts, and separate contracts could not be aggregated for the 183-day threshold unless they formed a coherent commercial and geographic whole. On the facts noted, each project remained below the threshold, so no permanent establishment arose in India on that basis. The commentary also notes that interest under section 234B was not leviable on the admitted facts, following binding jurisdictional precedent. en-us Fri, 12 Jun 2015 00:00:00 +0530 Mon, 09 Nov 2015 14:46:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=261152 A specific treaty rule for construction or installation projects governs subsea installation contracts under the India-Singapore DTAA, so Article 5(6) for services cannot override Article 5(3). The projects had to be tested separately on their own facts, and separate contracts could not be aggregated for the 183-day threshold unless they formed a coherent commercial and geographic whole. On the facts noted, each project remained below the threshold, so no permanent establishment arose in India on that basis. The commentary also notes that interest under section 234B was not leviable on the admitted facts, following binding jurisdictional precedent. Case-Laws Income Tax Fri, 12 Jun 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=261152