Double taxation agreement applies to residents of contracting states, authorising treaty provisions to govern income taxation across fiscal years. The notification implements the India-Kenya tax treaty domestically, providing that the Agreement's provisions apply in India in respect of income derived in any fiscal year beginning on or after the first fiscal year following the year of entry into force. Article 1 specifies that the Agreement applies to persons who are residents of one or both Contracting States, thereby defining the personal scope of the treaty for tax purposes.