https://www.taxtmi.com/caselaws?id=59214 A foreign enterprise has a permanent establishment in India only where its activities amount to a fixed and enduring business presence under Article 5 of the Double Taxation Agreement. A vessel, remotely operated vehicles and related inspection arrangements used for limited inspection and repair work on submarine pipelines did not create such a fixed place of business, because the vessel was only a moving instrument of operations and no substantial, enduring projection into India was shown. The enterprise therefore had no permanent establishment in India, and its business profits remained taxable only in the United Kingdom under Article 7. en-us Mon, 06 Oct 1997 00:00:00 +0530 Mon, 27 Dec 2010 11:56:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=59214 A foreign enterprise has a permanent establishment in India only where its activities amount to a fixed and enduring business presence under Article 5 of the Double Taxation Agreement. A vessel, remotely operated vehicles and related inspection arrangements used for limited inspection and repair work on submarine pipelines did not create such a fixed place of business, because the vessel was only a moving instrument of operations and no substantial, enduring projection into India was shown. The enterprise therefore had no permanent establishment in India, and its business profits remained taxable only in the United Kingdom under Article 7. Case-Laws Income Tax Mon, 06 Oct 1997 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=59214