https://www.taxtmi.com/caselaws?id=59732 For the nine-month threshold under Article 5(2)(i) of the India-Mauritius tax treaty, the duration test for a construction, assembly or supervisory project must be applied to each contract separately unless the Revenue shows artificial splitting or such interdependence that the activities form one coherent whole. Common principal, similar work, or the same oilfield is not enough to aggregate periods. Permanent establishment must therefore be examined contract-wise on actual project duration, and any individual contract must be tested on its own facts. en-us Mon, 22 Mar 2010 00:00:00 +0530 Sun, 03 Sep 2023 10:16:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=59732 For the nine-month threshold under Article 5(2)(i) of the India-Mauritius tax treaty, the duration test for a construction, assembly or supervisory project must be applied to each contract separately unless the Revenue shows artificial splitting or such interdependence that the activities form one coherent whole. Common principal, similar work, or the same oilfield is not enough to aggregate periods. Permanent establishment must therefore be examined contract-wise on actual project duration, and any individual contract must be tested on its own facts. Case-Laws Income Tax Mon, 22 Mar 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=59732