https://www.taxtmi.com/caselaws?id=305116 For a construction or installation project under the India-Cyprus DTAA, the treaty period for a Permanent Establishment is computed from the start of actual site-related contractual operations, while preparatory or tender-stage activity is excluded. On the facts, the project did not cross the 12-month threshold, and the Revenue did not discharge the burden of proving otherwise. No Permanent Establishment was therefore constituted under Article 5(2)(g), and the contract income was not taxable in India under Article 7. en-us Mon, 18 Nov 2019 00:00:00 +0530 Thu, 17 Nov 2022 21:50:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=305116 For a construction or installation project under the India-Cyprus DTAA, the treaty period for a Permanent Establishment is computed from the start of actual site-related contractual operations, while preparatory or tender-stage activity is excluded. On the facts, the project did not cross the 12-month threshold, and the Revenue did not discharge the burden of proving otherwise. No Permanent Establishment was therefore constituted under Article 5(2)(g), and the contract income was not taxable in India under Article 7. Case-Laws Income Tax Mon, 18 Nov 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=305116