{"url":"https://lrlabs.ai/t/stock_limb_elements_india_usa","engine":"deterministic","llm_in_path":false,"id":"stock_limb_elements_india_usa","question":"What does the India–US stock limb require beyond maintaining stock and delivering?","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)","confidence":"settled","as_at":"14 Aug 2026","treaty":"India–USA","quote":"some additional activities conducted in that State on behalf of the enterprise have contributed to the sale","quote_string_verified":true,"quote_source":"provision:IN-US.ART5"}