PE commence with performance of business activities in connection with building site or assembly project

CIT International Taxation Vs Bellsea Ltd. (Delhi High Court) HC held that duration of a permanent establishment would commence with the performance of business activities in connection with the building site or assembly project. A building site or an assembly project can only be construed at fixed place of business only when an enterprise commences its activities at the project site. Any activity which may be related or incidental but was not carried out at the site in the source country would clearly not be construed as a PE. Albeit, preparatory work at the site itself can be counted for th...