Section 4 in Agreement between the Government of the Republic of India and the Government of the Russian Federation for the avoidance of double taxation with respect to taxes on income
4. Notwithstanding the provisions of paragraphs 1 and 2, where a person-other than an agent of an independent status to whom paragraph 5 applies is acting in a Contracting State on behalf of an enterprise of the other Contracting State, that enterprise shall be deemed to have a permanent establishment in the first-mentioned Contracting State in respect of any activities which that person undertakes for the enterprise. if-
(a)he has, and habitually exercises in that State, an authority to conclude contracts or carryon any business activities on behalf of the enterprise, unless his activities are limited to those specified in paragraph 3 of this Article; or(b)he habitually secures orders for the sale of goods or merchandise in that State exclusively or almost exclusively on behalf of the enterprise or other enterprise controlled by it or which have a controlling interest in it; or(c)he has no such authority, but habitually maintains in the first-mentioned State a stock of goods or merchandise from which he regularly delivers goods or merchandise on behalf of the enterprise; or(d)in acting as described in (b) above he manufactures or process in that State for the enterprise. goods or merchandise belonging to the enterprise.
