Section 7 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
7. An enterprise shall be deemed to have a permanent establishment in a Contracting State and to carry on business through that permanent establishment if it provides services or facilities in connection with, or supplies plant and machinery on hire used for or to be used in the prospecting for, or extraction or exploitation of mineral oils in that State.
