http://www.dbriefsap.com/bytes/Dec2017_2.2017UpdatetoOECDModelTreatyandCommentary.pdf (page 81)
India does not agree with the view expressed in paragraph 5 of the Commentary on
Article 5 that by itself, treatment under VAT/GST is irrelevant for the purpose of interpretation
and application of the definition of permanent establishment. India considers that treatment
under VAT/GST can be a relevant factor for this purpose