Double taxation avoidance treaty prescribes residence based taxation, source exceptions for permanent establishments, and dispute resolution. Bilateral agreement between India and Syria to avoid double taxation on income, applying to residents and defining residence tie breakers and permanent establishment. It allocates taxing rights by income category-immovable property, business profits (profits attributable to a permanent establishment), shipping and air transport, dividends, interest and royalties (source taxation subject to specified withholding limits), capital gains and various personal services-and prescribes reciprocal tax credit methods to eliminate double taxation. The treaty also provides non discrimination, mutual agreement procedure, exchange of information with confidentiality protections, entry into force and termination rules.