Permanent establishment defined: fixed place or dependent agent activities can create taxable presence under DTAA. A permanent establishment is a fixed place of business through which an enterprise carries on business; examples include management, branch, office, factory, workshop, extraction sites, warehouse, farm and construction sites exceeding six months. Provision of services or supply of plant for mineral prospecting or extraction also creates a permanent establishment. Exclusions cover facilities used solely for storage, display, delivery, stock for processing, purchasing, information collection, or preparatory or auxiliary activities. Dependent agents who habitually conclude contracts, maintain delivery stock, or secure orders can create a permanent establishment, whereas independent agents acting in the ordinary course do not. Mere corporate control across States does not by itself create a permanent establishment.