No service PE if employee of Singaporean company had visited India for a period of only 2 days

IT/ILT : Where employees of assessee, foreign company had visited India for a period of only 2 days, pre-condition contained under article 5(6)(b) of India-Singapore DTAA was not satisfied and, accordingly, employees of assessee could not be considered as service PE in India and consequently, in absence of a PE in India, management fee received by assessee would not be subject to tax in India

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