Mumbai ITAT interprets Article 5 of India-Singapore DTAA to decide constitution of installation PE i

IT/ILT: The assessee, a tax resident of Singapore, had undertaken installation and construction activity in respect of certain projects. The DRP held that the presence of assessee in India in excess of 90 days constituted PE in India under Article 5(6) of India-Singapore DTAA. The ld. Counsel of assessee argued that threshold limit of 183 days was applicable as activities of assessee would fall within Article 5(3).ITAT held that as activities related to construction or installation are specifica