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

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