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Indo-UAE Tax Treaty- Aggregation of time spent on different projects can only arise for `connected’ projects
Case Law Details
- Case Name
- Valentine Maritime (Gulf) LLC Vs. ADIT (ITAT Mumbai)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2000- 2001
- Courts
- ITAT Mumbai
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DECIDED BY: ITAT, MUMBAI `L’ BENCH, MUMBAI, IN THE CASE OF: Valentine Maritime (Gulf) LLC Vs. ADIT (Int’l Taxation), APPEAL NO: ITA NO. 2879/MUM/05 DECIDED ON April 5, 2010
RELEVANT EXTRACTS:
7. Vide our order of even date, in the case of ADIT Vs Valentine Maritime (Mauritius) Limited, we have observed as follows :
The first issue that we must address ourselves to is whether or not, on the facts and in the circumstances of the case, the assessee can be said to have a PE in India. Article 5 (2)(i) of the Indo Mauritius tax treaty, which is broadly the same as Articl...
