Permanent Establishment under Article 5(2)(c) of the Double Taxation Avoidance Agreement between India and UAE

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Last updated: 13 July 2021
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This Income Tax Appellate Tribunal case concerns whether a construction project undertaken by the National Petroleum Construction Company in India, under the India-UAE Double Taxation Avoidance Agreement (DTAA), constituted a 'permanent establishment'. The revenue argued that the project created such an establishment, making the company liable for tax in India. The Tribunal's decision, detailed in the full judgement, clarifies the application of Article 5(2)(c) of the DTAA to such scenarios.

Court :
ITAT Delhi

Brief :
 This appeal filed by the revenue is preferred against the order of the CIT(A)-43, New Delhi dated 06.06.2017 for A.Y. 2011-12.

Citation :
ITA No.5563/Del/2017

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