Avoidance of double taxation: treaty allocates taxing rights, limits source withholding, and mandates information exchange. Convention sets a bilateral tax framework to avoid double taxation and prevent fiscal evasion between India and Korea, applying to residents and income taxes. It defines residence rules and a permanent establishment test (with exclusions and an agent rule) to allocate taxing rights over business profits and other income categories. The treaty prescribes source state withholding ceilings for dividends, interest, royalties and technical service fees where the recipient is beneficial owner, provides for elimination of double taxation by tax credits subject to domestic law and ceilings, and establishes mutual agreement and exchange of information mechanisms.