https://www.taxtmi.com/highlights?id=94828 HC upheld the Tribunal's finding that the non-resident assessee did not have a service PE in India under Art. 5(6) of the India-Singapore DTAA for AYs 2020-21 and 2021-22. It approved exclusion of 36 vacation days from the employees' 120-day physical presence, resulting in only 84 days in India, below the 90-day threshold. HC held that only actual days of service rendering in India are relevant and rejected the Revenue's contention of a "virtual service PE," noting that such a concept is absent from both the DTAA and the domestic statute. Appeals were dismissed against the Revenue. en-us Sat, 06 Dec 2025 08:46:10 +0530 Sat, 06 Dec 2025 08:46:11 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=94828 HC upheld the Tribunal's finding that the non-resident assessee did not have a service PE in India under Art. 5(6) of the India-Singapore DTAA for AYs 2020-21 and 2021-22. It approved exclusion of 36 vacation days from the employees' 120-day physical presence, resulting in only 84 days in India, below the 90-day threshold. HC held that only actual days of service rendering in India are relevant and rejected the Revenue's contention of a "virtual service PE," noting that such a concept is absent from both the DTAA and the domestic statute. Appeals were dismissed against the Revenue. Highlights Income Tax Sat, 06 Dec 2025 08:46:10 +0530 https://www.taxtmi.com/highlights?id=94828