If installation project by Singapore Company in India last for less than 183 days in a fiscal year then its profit not taxable in India

CA Suraj R. Agrawal Brief of the Case:- If the installation project last for less than 183 day in a fiscal year by a Singapore Company having no Permanent Establishment in India, then business profits of Such Company earned In India from Such project are taxable only in Singapore under article 7(1) of DTAA and Not taxable in India. Case Summary:- Facts of the case: 1. The Applicant is engaged in the business of heavy lifting and erection and installation of heavy equipments such as boilers, coke drums, fractionators, generators, chimneys, etc., for large projects at the proje...