No service PE without 90 days: only actual workdays count under Art. 5(6) India-Singapore DTAA

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....HC upheld the Tribunal's finding that the non-resident assessee did not have a service PE in India under Art. 5(6) of the India-Singapore DTAA for AYs 2020-21 and 2021-22. It approved exclusion of 36 vacation days from the employees' 120-day physical presence, resulting in only 84 days in India, below the 90-day threshold. HC held that only actual days of service rendering in India are relevant and rejected the Revenue's contention of a "virtual service PE," noting that such a concept is absent from both the DTAA and the domestic statute. Appeals were dismissed against the Revenue.....