Double taxation relief: treaty provides credit method and allocation rules to prevent income tax double taxation between India and Nepal. Agreement allocates taxing rights between India and Nepal for residents and specified income taxes, defines key terms including resident and permanent establishment, and prescribes when business profits, immovable property, dividends, interest, royalties and various categories of personal services may be taxed by each State. It provides a credit-based mechanism to eliminate double taxation subject to domestic law limits, sets withholding ceilings for certain cross-border payments, establishes a mutual agreement procedure and exchange-of-information framework, and contains non-discrimination, entry-into-force and termination provisions.