Word ‘used’ doesn’t include ready to use; unused rig wouldn’t constitute PE under India-USA DTAA; S

IT/ILT : Word 'used' as specified in article 5 of Indo USA DTAA clarifies usage of an installation or structure for exploration of natural resources and if it was so used for a period of 120 days in 12 months, only then it can be considered as PE in India and not merely being ready for use