Sen, J. - The advance ruling has been sought on the following questions of law :—

"1. Whether on the facts and in the circumstances, the applicant can be said to have a permanent establishment in India ?

2. Whether under paragraph 3(a) of Article 7 of the ADT agreement between India and Belgium, the profits attributable to the permanent establishment can be worked out on completed contract method ?

3. Though the said para 3(a) speaks of deduction of expenses, whether depreciation of allowance will be granted on dredgers, boats, equipment, computers and other plant and machinery deployed for the execution of the contract on the basis of cost of acquisition, since the said assets were not put to use in India any time before and no depreciation is ‘actually allowed’ under the Income-tax Act, 1961 ?

4. Whether repairs and maintenance expenses incurred before commencement of the contract and to be incurred immediately after completion of the contract on dry docking, etc., but relating to the execution of the contract, shall be allowed as deduction or could be capitalised on the cost of equipment, if depreciation is held allowable ?

5. Whether standing charges for the assets specific