Tribunal held that  from the facts and materials on record, it is quite clear that the assessee has furnished material evidences to demonstrate that the installation and commissioning services for the Bengaluru project commenced on 14th June, 2017 and ended on 29th July, 2027, aggregating to 46 days. Installation and commissioning services for the Gurugram project commenced on 8th Nov., 2017 and ended on 2nd Feb., 2018 lasting for a aggregate period of 87 days. Thus, in both the instances the threshold period of 183 days as provided in arts. 5(3) and 5(4) of the DTAA was not breached. The assessee has also demonstrated that both in terms of man-days and solar days, two projects will not constitute PE in India under arts. 5(3) and 5(4) of India Singapore DTAA. Accordingly the  service rendered in each projects sites did not exceed threshold limit of 183 days hence no profits out of sale equipments as well as installation and commissioning services can be taxed in India.  (AY. 2018-19 to 2020-21)