Project office used as communication channel is not PE

India-UAE DTAA-Project office used as communication channel is not a Permanent Establishment – Delhi High Court Brief of the Case Delhi High Court held In the case of National Petroleum Construction Company vs. DIT that in DIT (International Taxation) v. Morgan Stanley & Company Inc. (2007) 292 ITR 416 (SC), the Supreme Court held that the back office operations carried on at an office would fall within the exclusionary clause of Article 5(3) (e) of the Treaty between India and United States which is also identically worded as Article 5(3) (e) of the India-UAE DTAA. Further the Oxford D...