India-Singapore DTAA Case: Project Duration Under 183 Days, Not a Service Permanent Establishment, Assessment Rejected.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....Service PE in India - India Singapore DTAA - Service PE or Not - the threshold of the time limit as calculated by the AO from the date of signing of agreement cannot be accepted. - the number of days is far below than 183 days - project does not constitute service PE in India - AT....