[ compiled answer ]
law as at 14 Aug 2026 · settled
What does the India–US stock limb require beyond maintaining stock and delivering?
The compiled answer
Article 5(4)(b) opens with a precondition — the person has NO authority to conclude contracts ("he has no such authority, but…") — and then requires habitual maintenance of a stock, regular delivery from it, AND that additional activities conducted in India on the enterprise's behalf contributed to the sales. The sales-contribution conjunct is an India–US addition absent from the OECD pattern; stock plus delivery alone does not complete the limb. (Domestic Explanation 2(b) to s.9(1)(i) carries no such conjunct — the treaty is narrower and prevails for a treaty-entitled enterprise via s.90(2).)
Pinpoint
Article 5(4)(b), India–US DTAA (1990)
String-verified quote
“some additional activities conducted in that State on behalf of the enterprise have contributed to the sale”
source: provision:IN-US.ART5 — verified at load; a quote that stops matching its source is a compile error
Computed by a deterministic engine over compiled law — no generative model in the evaluation path. JSON twin: /t/stock_limb_elements_india_usa.json · Ask with YOUR facts: GET /compute?lookup=… · MCP: POST https://lrlabs.ai/mcp (lookup_compiled_rule)