Indo-German DTAA – As per new Treaty, income from supervision activity like construction & installation of a project is to be treated as income of PE provided that said activity continues for a period exceeding six months as per article 5(2)(i) of DTAA

DECIDED BY: ITAT, Bench `L’, Mumbai, IN THE CASE OF: ADIT(IT) Vs. Krupp UHDE GMBH,  APPEAL NO: ITA No. 4496 & 4652/Mum/2005, DECIDED ON January 28, 2010

Order
Per:

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