Double taxation avoidance - treaty allocates taxing rights, limits source withholding, and provides mutual dispute resolution. Convention allocates taxing rights between India and Japan to avoid double taxation and fiscal evasion, applying to residents and specified taxes; it defines residence and a broad concept of permanent establishment with time and activity thresholds, prescribes attribution of profits to permanent establishments on an arm's-length basis, sets source-state ceilings for dividends, interest and royalties where recipient is beneficial owner, and provides mechanisms for relief from double taxation through credit/deduction, non-discrimination protections, a mutual agreement procedure for resolving treaty application disputes, and exchange of tax information subject to confidentiality and domestic law limits.