No Permanent Establishment for DHR India under Articles 5(8) and 5(9) of India-Singapore Tax Treaty.

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....Permanent Establishment (PE) in India - attribution of profit to the PE - Revenue authorities have not brought any material on record to demonstrate that the activities of DHR India are wholly devoted on behalf of the assessee and as such it does not have any independent status and was not acting in the ordinary course of its business. - there cannot be any PE under Article 5(8) and 5(9) of the Indian – Singapore Tax Treaty. - AT....