Held that   since the assessee had no permanent establishment in India, income earned by it as business profits in India would not be taxable in India by virtue of the provisions of article 7 of the Double Taxation Avoidance Agreement between India and Malaysia according to which a tax resident of Malaysia would be taxable in India to the extent of the profits attributable to the permanent establishment in India only if it carried on business through a permanent establishment in India. The enterprises would be taxable only to the extent article 5 of the Double Taxation Avoidance Agreement defined the permanent establishment as inter alia a place of management, a branch, an office, a factory, a warehouse and a workshop.(AY.1999-2000)