https://www.taxtmi.com/caselaws?id=440293 For Article 5(5) of the India-Singapore DTAA read with section 44BB, the 183-day period begins when the rig enters India and starts connected preparatory and operational activities, not only when actual drilling commences. The court treated upgrades, repairs, positioning and other preparatory work as integral to the offshore drilling services linked to exploration or extraction of mineral oil, so the threshold was satisfied. On that basis, the assessee was treated as having a presence in India for more than 183 days, and the challenge to taxability failed. en-us Wed, 05 Jul 2023 00:00:00 +0530 Tue, 18 Nov 2025 11:18:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=440293 For Article 5(5) of the India-Singapore DTAA read with section 44BB, the 183-day period begins when the rig enters India and starts connected preparatory and operational activities, not only when actual drilling commences. The court treated upgrades, repairs, positioning and other preparatory work as integral to the offshore drilling services linked to exploration or extraction of mineral oil, so the threshold was satisfied. On that basis, the assessee was treated as having a presence in India for more than 183 days, and the challenge to taxability failed. Case-Laws Income Tax Wed, 05 Jul 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=440293