Permanent establishment: fixed place or dependent-agent presence can create taxable nexus under DTAA, subject to specified exclusions. Permanent establishment is a fixed place of business through which an enterprise's business is carried on, including specified sites and service-provision by personnel where duration thresholds are met. Exclusions cover places used solely for storage, display, processing by others, purchasing, information collection, and preparatory or auxiliary activities. A dependent agent habitually concluding contracts or maintaining stock to fulfill orders creates a permanent establishment, whereas independent agents acting in the ordinary course do not; exclusive or near-exclusive devotion negates independent status. Corporate control alone does not constitute a permanent establishment.