Limitation of benefits: qualification and anti abuse rules determine entitlement to treaty benefits and prevent treaty shopping. Article 28 conditions DTAA benefits on status as a qualified person-including governmental entities, listed companies, resident owned companies, resident majority partnerships, and resident charitable or tax exempt entities-and disqualifies entities paying most gross income to non residents via deductible payments, subject to ordinary course and banking carve outs. Benefits also arise if the resident actively carries on business in the State of residence and income is connected to that business. The Competent Authority may permit benefits absent principal purpose of treaty shopping; recognised stock exchanges are defined and mutual recognition is permitted. An overarching anti abuse rule denies benefits for arrangements whose main purpose is tax avoidance.