Exchange of information expanded to require and protect broader cross border tax disclosure while enabling authorized administrative uses. The Protocol requires that profits of a permanent establishment be determined by the remuneration attributable to the PE's actual activity rather than on gross contract value, preserves taxation of head office profits in the resident State, precludes attribution of profits merely for facilitation of foreign trade or loan agreements, and ensures minimum allowance for executive and general administrative expense deductions not less than that under the Indian Income tax Act as at signature. It also replaces Article 26 to broaden Exchange of Information obligations, treating received information as secret while permitting authorized uses and obliging States to obtain requested information including bank and fiduciary records subject to limited exceptions.