2016 (9) TMI 119

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....ent : I.P.S. Bindra and S.S. Negi RULING V.S. Sirpurkar, J.- The applicant Tiong Woon Project & Contracting (Pte) Ltd. is a tax resident of Singapore. It has raised two questions which are as under:- (i) Whether looking to the nature of activities carried on by the Applicant, which is a Singapore based company and a non-resident as per the provisions of Section 6(3) of the Income Tax A....

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....s commencing from 17.02.2015, which is expected to end on 15.09.2015 to M/s. GR Engineering Private Limited. This renting is claimed to have been done by the applicant as per the terms contained in the Service Work Order No. P11/744-3400001617 dated 04.03.2014 and Amendment Service Order dated 03.06.2014. The applicant has given a break up of the total consideration of Rs. 19.45 crores. It is furt....

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....uring the period 6.1.2011 to 31.01.2012 for M/s. Punj Lloyd Limited by using a crane imported in November, 2007; and (iii) the third relates to the erection and installation of certain equipment of the customer at M/s. Bramhaputra Craker & Polymer Limited, Lepetkata, Assam during the period 15.4.2012 to 9.10.2012 for M/s. Bramhaputra Craker & Polymer Limited by using two cranes imported in Novembe....

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.... stand in the reply that the installation of project was carried out by the applicant for 'G.R. Engineering Private Limited at BPCL, Kochi, Kerala commencing on 16.2.2015 and expected to end on 31.01.2016 constitutes a Permanent Establishment of the applicant in India in terms of Article 5 paragraph 3 of India-Singapore Double Tax Avoidance Agreement (DTAA) and hence, the business profits attr....