https://www.taxtmi.com/caselaws?id=782961 Under Article 5(6) of the India-Singapore DTAA, a service permanent establishment arises only where services are actually furnished in India through employees or other personnel for more than 90 days in the relevant fiscal year. Mere physical presence is insufficient, and days on which no client services were rendered were excluded, leaving the threshold unmet; no service permanent establishment existed. The DTAA also contains no concept of a virtual service permanent establishment, and treaty terms cannot be expanded by reference to digitalisation, OECD developments, or domestic policy such as significant economic presence. Accordingly, no permanent establishment arose under the treaty. en-us Thu, 04 Dec 2025 00:00:00 +0530 Sat, 06 Dec 2025 08:46:09 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=782961 Under Article 5(6) of the India-Singapore DTAA, a service permanent establishment arises only where services are actually furnished in India through employees or other personnel for more than 90 days in the relevant fiscal year. Mere physical presence is insufficient, and days on which no client services were rendered were excluded, leaving the threshold unmet; no service permanent establishment existed. The DTAA also contains no concept of a virtual service permanent establishment, and treaty terms cannot be expanded by reference to digitalisation, OECD developments, or domestic policy such as significant economic presence. Accordingly, no permanent establishment arose under the treaty. Case-Laws Income Tax Thu, 04 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=782961