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No PE in India if oil wells weren’t at disposal of assessee to extract mineral oil: ITAT

November 1, 2018[2018] 99 21 (Delhi - Trib.)

IT : Where assessee, a company incorporated in Mauritius, was acting as a sub contractor with HHI and valentine Consortium for certain specialized job of extraction or mineral oil in India on ONGC Mumbai Uran terminal water projects, decision of Commissioner (Appeals) that assessee had a PE under article 5(2)(f) of DTAA between India and Mauritius was incorrect as Commissioner (Appeals) had not at all examined that whether oil well or gas was fixed place available to assessee for carrying on its business and unless that was proved first by revenue, income could not be charged under that article

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