Double taxation avoidance treaty allocates taxing rights, limits source taxation on dividends, interest, royalties; provides mutual agreement and information exchange. The Convention allocates taxing rights between India and Kenya for residents, applies to income taxes (including substantially similar future taxes), and defines residence with tie breaker rules. Business profits are taxable in the State of residence unless attributable to a permanent establishment in the other State, with profits attributed on an arm's length/separate enterprise basis. Source taxation of dividends, interest, royalties and management/professional fees is limited by specified maximum withholding rates but yields to PE/fixed base connection. The treaty provides unilateral credit methods to eliminate double taxation, non discrimination protections, a mutual agreement procedure, and exchange of information safeguards.