https://www.taxtmi.com/caselaws?id=790900 For determining the service PE threshold under Article 5(2)(l) of the India-USA DTAA, the relevant period is computed on the basis of unique solar days of service presence in India, not by aggregating overlapping man-days for individual employees. Applying jurisdictional precedent, the Tribunal held that the focus is on the continuation of service activity in India within the treaty period. On the facts, the employees were present for only 72 unique solar days, below the 90-day threshold, so no service PE arose in India and the addition was deleted. en-us Thu, 30 Apr 2026 00:00:00 +0530 Sat, 02 May 2026 07:40:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=790900 For determining the service PE threshold under Article 5(2)(l) of the India-USA DTAA, the relevant period is computed on the basis of unique solar days of service presence in India, not by aggregating overlapping man-days for individual employees. Applying jurisdictional precedent, the Tribunal held that the focus is on the continuation of service activity in India within the treaty period. On the facts, the employees were present for only 72 unique solar days, below the 90-day threshold, so no service PE arose in India and the addition was deleted. Case-Laws Income Tax Thu, 30 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=790900