Whether the different periods of the contracts are to be aggregated to reckon the threshold of 183 days under clause 5.3 of the DTAA with Singapore to determine PE?

In Re Tiong Woon Project & Contracting Pte. Limited Vs. ADIT (International Taxation), Chennai (AAR)- Whether the different periods of the contracts are to be aggregated to reckon the threshold of 183 days under Article 5.3 of the DTAA in a fiscal year in a case where the projects are not carried out for the same principal. We notice that Naftogaz India had given two orders: one order in FY 2009-10 and another in FY 2010- 11. These are to carry out different work: one is for the erection of Coke Drum and Fractionators’column at Bina and other for erection of equipment at CDSP unit or GGS...