https://www.taxtmi.com/caselaws?id=189727 Mere supervisory and technical assistance at an Indian customer's site did not amount to carrying on an installation project for treaty permanent establishment purposes. The Tribunal read the relevant treaty language, including the six-month building site or construction/installation threshold, and found no material difference between the 1985 and 1960 wording on this point. Because the Indian concern carried out the actual erection and installation, supervision alone was not treated as installation and could not be stretched into a permanent establishment in India. The related profits were therefore not taxable in India on that basis. en-us Fri, 23 Aug 1996 00:00:00 +0530 Wed, 18 Jan 2017 17:47:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=189727 Mere supervisory and technical assistance at an Indian customer's site did not amount to carrying on an installation project for treaty permanent establishment purposes. The Tribunal read the relevant treaty language, including the six-month building site or construction/installation threshold, and found no material difference between the 1985 and 1960 wording on this point. Because the Indian concern carried out the actual erection and installation, supervision alone was not treated as installation and could not be stretched into a permanent establishment in India. The related profits were therefore not taxable in India on that basis. Case-Laws Income Tax Fri, 23 Aug 1996 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=189727