https://www.taxtmi.com/caselaws?id=181736 Treaty provisions under the India-Singapore double taxation agreement override the general charging provisions of the Income-tax Act, 1961. Revenues from offshore pipeline burial contracts were examined on the basis of whether the Singapore resident had a permanent establishment in India under Article 5 and whether Article 7 allowed taxation of the profits. The activities were not carried on through a fixed place of business, and the work was treated as an installation and assembly project under Article 5(3). Because the project did not continue for more than 183 days in any fiscal year, no permanent establishment arose in India, and no profits were attributable to any Indian establishment. The revenues were therefore not taxable in India. en-us Fri, 09 Feb 1996 00:00:00 +0530 Wed, 03 Aug 2016 11:39:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=181736 Treaty provisions under the India-Singapore double taxation agreement override the general charging provisions of the Income-tax Act, 1961. Revenues from offshore pipeline burial contracts were examined on the basis of whether the Singapore resident had a permanent establishment in India under Article 5 and whether Article 7 allowed taxation of the profits. The activities were not carried on through a fixed place of business, and the work was treated as an installation and assembly project under Article 5(3). Because the project did not continue for more than 183 days in any fiscal year, no permanent establishment arose in India, and no profits were attributable to any Indian establishment. The revenues were therefore not taxable in India. Case-Laws Income Tax Fri, 09 Feb 1996 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=181736