whether installation PE commences from the date of kick off meeting ?

Relevant tax treaty provides for 6 months duration for construction PE. Foreign company has undertaken a supply and installation project in India. After executing contract a kick off meeting was held to discuss the specifications of equipment to be supplied and installed. Q1 - whether installation PE commences from the date of kick off meeting ? After supply of one lot of equipment the installation had to be stopped as remaining supplies got delayed due to unavoidable reasons like shortage of material etc. After supply of remaining materials the installation resumed. Q2 - whether interim period during which installation was…

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