India–Netherlands DTAA-Mere provision of a dredger on dry lease for carrying out dredging activity in India does not result in assessee having a PE

DECIDED BY: ITAT, MUMBAI BENCH `A’, MUMBAI, IN THE CASE OF: DDIT Vs. Nederlandsche Overzee Baggermaatschappiji B.V., APPEAL NO: ITA Nos. 8352/Mum/2004, 8888/Mum/2004, 1542/Mum/2005 and 2118/Mum/2006 C.O. No. 256/Mum/2006, DECIDED ON May 14, 2010 O R D E R Per J. Sudhakar Reddy, A.M. All these appeals are filed by the Department. The Cross Objection is filed by the assessee for the assessment year 2002-03. As the issues arising in all these appeals are common, for the sake of convenience, they are heard together and disposed of by way of this common order. 2. Fact in brief: The AO in his ...