Foreign Permanent Establishment profits may be taxed in India

Under Article 7 of DTAA, foreign Permanent Establishment profits may be taxed in India

Other items of income or capital may not be taxed in the State of source or situs; as a rule they are taxable only in the State of residence of the taxpayer. This applies, for example, to royalties (Article 12), gains from the alienation of shares or securities (paragraph 5 of Article B), private sector pensions (Article 18), payments received by a student for the purposes of his education or training (Article 20), and capital represented by

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