IT/ILT: Period of stay of Independent Project offices shall not be aggregated to determine number of days of stay in India - If number of days of stay of each project office in India does not exceed 180 days, no PE shall be deemed to be in existence in India - Supervisory fees shall not be deemed to be connected with Liaison Office, being a PE in India, if such LO is nowhere involved in the supervisory activities - Hence, Supervisory fees shall be taxable as FTS under Article 12 and not as Busin
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