Revenue Authorities Must Prove 12-Month Threshold for Permanent Establishment in India under Article 5(2)(g) for Taxation.

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....Establishment of Permanent Establishment (PE) in India - Onus is heavily upon the revenue to establish that that assessee’s activity had crossed the threshold period of 12 months and hence constitutes PE in India in terms of Article 5(2)(g) so as to tax the receipts in India as per Article 7.....