India- Singapore DTAA – Installation project less than 183 days not constitute PE, income not taxable in India– AAR

Brief of the Case Authority for Advance Rulings held In the case of Tiong Woon Project & Contracting (Pte) Ltd. that the department has correctly provided a positive response that because the project was continued in India only for 178 days in a fiscal year, it will not be treated as a permanent establishment and the business profits will be taxable only in the country where the applicant is resident i.e. in Singapore as per Article 7.1 of India-Singapore DTAA. Facts of the Case The Applicant is engaged in the business of heavy lifting and erection and installation of heavy equipments suc...