Tax treaty limits source taxation and sets PE rules, withholding caps, and mutual procedures to avoid double taxation. The notification gives effect in India to the India-South Africa income tax Agreement which allocates taxing rights between residents and source States, defines residency and permanent establishment, limits source withholding on certain cross border income subject to beneficial owner and permanent establishment exceptions, prescribes methods for elimination of double taxation by deduction or credit, and establishes mutual agreement, information exchange, and assistance in recovery procedures, together with entry into force, transitional application and termination rules.