Section 6 in The Agreement between the Government of Republic of India and the Government of Republic of Belarus for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes of income
6. The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State or which carries on business in that other Contracting State (whether through a permanent establishment or otherwise), shall not of itself constitute either company a permanent establishment of the other.
