This article examines the 2007 judgment of the Supreme Court of India in Morgan Stanley from the attribution side of Art. 7 and from the perspective of the permanent establishment (PE) triggering factors in Art. 5. Before examining the decision, the article discusses where the OECD currently stands regarding certain aspects of profit attribution and describes the axiom of the OECD system: the "all determinative" functions, which serve as the magnet for assets, risks and capital; agency PEs and administratively simplified assessments; and double taxation relief. The article also discusses the 2007 decision of the Income Tax Appellate Tribunal of Mumbai in SET Satellite and its choice for the OECD dual taxpayer approach. The article concludes that, contrary to the opinion of others, a close reading of Morgan Stanley indicates support for the dual taxpayer approach.