Tax treaty interpretation clarifies permanent establishment expense allocation and mutual agreement procedure obligations under DTAA. The Protocol clarifies that expenses of a permanent establishment are those directly connected with its activity; royalties, commissions and interest are deductible only to the extent of actual reimbursed expenses and as admissible under the taxation laws of the State where the permanent establishment is situated. It further provides that India's 'loans or debts' require governmental approval, treats certain public body remunerations as government service, defines Indian tax exempt or reduced amounts by reference to specified Income Tax Act provisions or substantially similar measures agreed by competent authorities, and confirms the mutual agreement procedure does not replace national remedies.