Double Taxation Agreement establishes residency-based treaty coverage and takes effect in India under domestic implementing authority. The Central Government, under section 90 of the Income-tax Act, gives effect in India to the India-Malaysia DTAA, formalising its operative commencement in Indian law and directing that the DTAA's provisions apply; the Agreement applies to persons who are residents of one or both Contracting States, making residency the primary nexus for treaty benefits.