https://www.taxtmi.com/caselaws?id=33951 The Authority determined that the applicant did not have a Permanent Establishment (PE) in India due to the project duration being less than 9 months. As a result, the contract price for laying pipelines under the sea was not subject to tax in India under the Income-tax Act and the India-Mauritius Tax Treaty. Other issues such as income attribution, applicability of Section 44BB for presumptive tax, and withholding tax rate were not addressed given the primary ruling on the absence of a PE. The decision was rendered on 26th June 2009. en-us Fri, 26 Jun 2009 00:00:00 +0530 Sat, 05 Sep 2009 13:02:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=33951 The Authority determined that the applicant did not have a Permanent Establishment (PE) in India due to the project duration being less than 9 months. As a result, the contract price for laying pipelines under the sea was not subject to tax in India under the Income-tax Act and the India-Mauritius Tax Treaty. Other issues such as income attribution, applicability of Section 44BB for presumptive tax, and withholding tax rate were not addressed given the primary ruling on the absence of a PE. The decision was rendered on 26th June 2009. Case-Laws Income Tax Fri, 26 Jun 2009 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=33951