Revised DTAA expands source-based capital gains taxation and lowers withholding burdens while enabling MAP and APA mechanisms. The revised DTAA establishes source based taxation for capital gains on substantial shareholdings, reduces withholding tax rates on royalties/technical fees and interest to facilitate cross border investment, expands dependent agent Permanent Establishment rules, and provides exclusive residence taxation for international shipping income. It creates explicit access to the Mutual Agreement Procedure and bilateral Advance Pricing Agreements for transfer pricing disputes, provides for suspension of tax collection during MAP on security, updates Exchange of Information to international standards including bank information, adds assistance in collection, and inserts a Limitation of Benefits anti abuse article.