Section 4(f) 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
(f)the maintenance of a fixed place of business solely for any combination of activities mentioned in sub-paragraphs (a) to (e), provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character.
