Double taxation convention applies to residents, making residency the connecting factor for treaty relief and obligations. The notification directs that the Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital between India and the Czech Republic shall be given effect in India under the Income-tax Act, 1961 and the Wealth-tax Act, 1957. The Convention's personal scope provides that it applies to persons who are residents of one or both Contracting States, making residency the connecting factor for treaty application.