Section 6 in Agreement between the Government of the Republic of India and the Government of the Republic of South Africa for the Avoidance of double taxation and the prevention of fiscal evasion with respect to Taxes on income
6. An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that State through a broker, general commission agent or any other agent of an independent status, provided that such persons are acting in the ordinary course of their business.
