Any other establishment that may be agreed from time to time between the competent authorities of the States Parties; and, in both cases, conditions different from those which would be made between independent undertakings are imposed or imposed between the two undertakings in their commercial or financial relations, and then all profits which, without those conditions, would have been paid to one of the undertakings but which have not been generated in that way as a result of those conditions; can be included in the profits of that business and taxed accordingly. 1. The attached Agreement between the Government of the Republic of India and the Government of the French Republic for the avoidance of double taxation and the prevention of fiscal evasion on the tax system of income and property is adopted on 1 August 1994, after the two States Parties have completed the procedures necessary under their law for the implementation of the said Convention, in accordance with paragraph 1 of Article 30 of that Convention; 12. The scholarly addl. Director misread and misinterpreted the provisions of Article 8(1), Article 8(1), Article 8(3) and Article 8(4) of the DBAA between India and France and grossly applied them to the applicant`s facts and circumstances. With regard to the facts and circumstances of the case, the Ld. . .