2015 (12) TMI 840

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....cant : Mr. K. Meenakshi Sundaran, FCA For the Department : Ms Sukhvinder Khanna, CIT-DR,AAR,ND Mr. S.S. Negi, JCIT-DR, AAR, ND Mr. Sachin Dhania, DCIT-DR(AAR),ND RULING ( V. S. Sirpurkar ) The applicant is Tiong Woon Project & Contracting (Pte) Limited, 15 Pandan Street, Singapore. 2. The Applicant is engaged in the business of heavy lifting and erection and installation of heavy eq....

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....referred herein, as per the provisions of Income Tax Act, 1961? 2. If the answer to the above question is affirmative, how the total income of the Applicant should be computed as per the provisions of the Income Tax Act, 1961? 5. In the application, it is stated, the applicant completed their installation project, which is covered by Article 5.3 of the India-Singapore Treaty. In fact, ....

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.... for 178 days in a fiscal year and as the duration of the project is less than 183 days in a fiscal year, Permanent Establishment of the applicant cannot be constituted in India for the FY 2012-13 as per the provisions of Article 5.3 of the India-Singapore DTAA. 6.2.5 Hence, it is submitted that the business profits accruing or arising to the applicant by way of the execution of the proje....