The Mumbai Income Tax Appellate Tribunal has recently issued its decision on whether time spent on separate projects may be aggregated for the purpose of determining the existence of a permanent establishment under the India-Mauritius tax treaty. The case involved a Mauritius-based company that was engaged in installation and construction work for offshore oil exploration platforms. The company entered into three separate contracts with an unrelated party for projects in three different locations in India. In its tax return, the company determined that it had no permanent establishment (PE) in India, because the time spent for each project was less...