The Government of India today signed an Agreement for Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital (DTAA) with Government of Georgia. The Agreement was signed today by Mr. M.C.Joshi, Chairman, Central Board of Direct Taxes(CBDT) on behalf of the Government of India and Mr. Zurab Katchkatchishvili, Ambassador of Georgia to India on behalf of the Government of Georgia.
-Tribunal in the assessment order 1995-96 as well as the appellate authority in the assessment order 1994-95 have categorically given a finding of fact that the entire duration of the contract was from 27th December, 1993 till 26th June, 1994, i.e., less than six months. Article 5 (3) of the treaty provided that in order to constitute a permanent establishment such site or project should continue for a period of more than six months.
An Indian Citizen who stays abroad for employment/carrying on business or vocation outside India or stays abroad under circumstances indicating an intention
