When companies sell/financial lease their products or provide services through websites or app markets, the income from such transactions is income from business.
The domestic laws of contracting state imposes tax the business income of the non-residents arising in their states only if the non-resident has the economic presence in the contracting state. The economic presence in a contracting state is generally defined in domestic laws of the contracting state as existence of either ‘business connection’ or ‘permanent establishment’ (PE). For example: Indian Income Tax Act taxes the business income arising to non-resident in India through or from a business connection.