https://www.taxtmi.com/caselaws?id=430407 Preparatory activity undertaken for tendering or obtaining a contract does not count towards the twelve-month threshold for a building, construction, assembly or installation project permanent establishment under Article 5(2)(g) of the India-Cyprus Treaty. The relevant period begins only when business activities at the site actually commence, and travel or other auxiliary steps taken before execution of the contract are excluded. On the facts, site work was found to have started only on or after 4 January 2008, with no perversity in the Tribunal's findings on the project dates. No permanent establishment was established, and the contract receipts were not taxable in India under Article 7. en-us Tue, 15 Nov 2022 00:00:00 +0530 Wed, 13 Dec 2023 15:18:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=430407 Preparatory activity undertaken for tendering or obtaining a contract does not count towards the twelve-month threshold for a building, construction, assembly or installation project permanent establishment under Article 5(2)(g) of the India-Cyprus Treaty. The relevant period begins only when business activities at the site actually commence, and travel or other auxiliary steps taken before execution of the contract are excluded. On the facts, site work was found to have started only on or after 4 January 2008, with no perversity in the Tribunal's findings on the project dates. No permanent establishment was established, and the contract receipts were not taxable in India under Article 7. Case-Laws Income Tax Tue, 15 Nov 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=430407