https://www.taxtmi.com/caselaws?id=345619 Article 5(5) of the India-Singapore DTAA deems a permanent establishment to exist where services or facilities connected with mineral oil exploration are provided for more than 183 days in a fiscal year. The text explains that, on the stated facts, a rig's arrival was followed immediately by fabrication, upgradation, positioning and other enabling work for the contracted drilling operations, and that this preparatory phase formed part of the deployment for the oil-field service. It rejects a narrow approach that counts only actual drilling days, treating the active preparation of the rig as included in the service period for PE computation and related Indian taxability under section 44BB. en-us Wed, 19 Apr 2017 00:00:00 +0530 Fri, 21 Jul 2017 10:52:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=345619 Article 5(5) of the India-Singapore DTAA deems a permanent establishment to exist where services or facilities connected with mineral oil exploration are provided for more than 183 days in a fiscal year. The text explains that, on the stated facts, a rig's arrival was followed immediately by fabrication, upgradation, positioning and other enabling work for the contracted drilling operations, and that this preparatory phase formed part of the deployment for the oil-field service. It rejects a narrow approach that counts only actual drilling days, treating the active preparation of the rig as included in the service period for PE computation and related Indian taxability under section 44BB. Case-Laws Income Tax Wed, 19 Apr 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=345619