Avoidance of double taxation: treaty allocates taxing rights by residence, permanent establishment and income category for cross-border income. The India-Qatar Agreement, given effect under section 90 of the Income-tax Act, applies to residents and taxes on income of each State and defines key terms. It allocates taxing rights by income type: immovable property to source State; business profits to resident State unless attributable to a permanent establishment in the other State; shipping profits to the State of residence of the enterprise; and sets withholding limits on dividends, interest, royalties and fees for technical services, with exceptions for amounts effectively connected to a permanent establishment. It provides for mutual agreement procedures, exchange of information, collection assistance, non-discrimination, and bilateral elimination of double taxation by tax credit.