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ITAT rules no Permanent Establishment under India-Cyprus Treaty; 12-month threshold not met due to preparatory visits.
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....PE in India - employees visiting India prior to the date of contract - scope of Article 5(2)(g) of India Cyprus Treaty - As per ITAT threshold period of twelve months has not been exceeded in present case and consequently no Permanent Establishment (‘PE’) can be said to have been established - preparatory work like travelling for obtaining tender/contract cannot be deemed to be the starting point of the contract - order of ITAT sustained - HC....