included the
number of days estimated to have been spent for supervisory
activities before the actual commencement of construction
work. Accordingly, by treating ... business activities have been carried out which could
be called as independent business activities yielding separate/
independent business profits. Thus, the aforesaid activity
product which makes the conclusion of
performed supervisory establishing supervisory PE (erroneously mentioned as
activities in service PE by the Ld. AO) of the assessee ... supervisory PE and assembly PE. The Ld. DRP noted that AO
in the DAO had discussed in detail that the assessee was performing supervisory
activities
building site or construction or assembly project or
supervisory activities in connection therewith, but only where such
site, project or activity continues for a period ... include:
.............
.............
..............
(i) a building site or construction or assembly
project or supervisory activities in connection
therewith, where such site, project or supervisory
activity continues
building site or construction or assembly project or
supervisory activities in connection therewith, but only where such
site, project or activity continues for a period ... include:
.............
.............
..............
(i) a building site or construction or assembly
project or supervisory activities in connection
therewith, where such site, project or supervisory
activity continues
erred in characterizing revenue from
supervisory activities, for a period exceeding the threshold
provided under the DTAA, as FTS in terms of Article ... activities were
carried out. He observed that the period of activity was only 30 days in
the FY 2013-14. Therefore, the supervision activity
erred in characterizing revenue from
supervisory activities, for a period exceeding the threshold
provided under the DTAA, as FTS in terms of Article ... activities were
carried out. He observed that the period of activity was only 30 days in
the FY 2013-14. Therefore, the supervision activity
erred in characterizing revenue from
supervisory activities, for a period exceeding the threshold
provided under the DTAA, as FTS in terms of Article ... activities were
carried out. He observed that the period of activity was only 30 days in
the FY 2013-14. Therefore, the supervision activity
erred in characterizing revenue from
supervisory activities, for a period exceeding the threshold
provided under the DTAA, as FTS in terms of Article ... activities were
carried out. He observed that the period of activity was only 30 days in
the FY 2013-14. Therefore, the supervision activity
erred in characterizing revenue from
supervisory activities, for a period exceeding the threshold
provided under the DTAA, as FTS in terms of Article ... activities were
carried out. He observed that the period of activity was only 30 days in
the FY 2013-14. Therefore, the supervision activity
erred in characterizing revenue from
supervisory activities, for a period exceeding the threshold
provided under the DTAA, as FTS in terms of Article ... activities were
carried out. He observed that the period of activity was only 30 days in
the FY 2013-14. Therefore, the supervision activity
