Rule of 'force of attraction' given in Article 7 of UN Model Treaty can't be imported into Article 7

IT/ILT : Article 7(1) of UN Model Convention which are materially different from the provisions of Article 7(1) of the India-UK DTAA read with Article 7(3) thereof. Articles 7(1)(b) and 7(1)(c) of the UN Model Convention as well as of the UN Model Convention Commentary cant be relied upon to come to a conclusion that the connotations of "profits indirectly attributable to permanent establishment" used in Article 7(1) of the Indo-UK treaty incorporates a force of attraction rule thereby bringing