https://www.taxtmi.com/caselaws?id=343582 Receipts from services rendered under the Arcadia Shipping contract were treated as taxable under section 44BB because the assessee conceded liability, so the earlier relief on that income could not stand. For the other two contracts, separate and unconnected projects with durations of less than nine months could not be aggregated to meet the India-UAE DTAA permanent establishment threshold under Article 5(2)(h). The assumption of earlier personnel presence was rejected as unsupported, and the Revenue's attempt to rely on a different treaty article was not accepted. The result was that the Revenue succeeded only on the Arcadia Shipping receipts, while the deletion of addition for the other contracts was sustained. en-us Wed, 24 May 2017 00:00:00 +0530 Fri, 26 May 2017 12:37:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=343582 Receipts from services rendered under the Arcadia Shipping contract were treated as taxable under section 44BB because the assessee conceded liability, so the earlier relief on that income could not stand. For the other two contracts, separate and unconnected projects with durations of less than nine months could not be aggregated to meet the India-UAE DTAA permanent establishment threshold under Article 5(2)(h). The assumption of earlier personnel presence was rejected as unsupported, and the Revenue's attempt to rely on a different treaty article was not accepted. The result was that the Revenue succeeded only on the Arcadia Shipping receipts, while the deletion of addition for the other contracts was sustained. Case-Laws Income Tax Wed, 24 May 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=343582