Double taxation agreement between India and Nepal governs tax treatment of resident persons and prevents fiscal evasion across jurisdictions. The India-Nepal Agreement for the avoidance of double taxation and the prevention of fiscal evasion has been notified under section 90 of the Income-tax Act, 1961 to be given effect in India, with the treaty's provisions applying in India for income derived in fiscal years beginning on or after the treaty's effective date. Article 1 provides that the Agreement applies to persons who are residents of one or both Contracting States, making residency the controlling criterion for access to treaty benefits.