Grouting falls under construction activity; no PE as per India-UAE DTAA if it was carried out for less than 9 months

IT/ILT : Grouting activity carried out to protect subsea pipelines, cables and structures falls under head construction activity as specified in article 5(2)(h) of Indo-UAE DTAA; where it was carried out for less than 9 months, assessee UAE company could not be said to have a PE in India

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