Double taxation avoidance: treaty applies to persons resident in one or both contracting states and is given domestic effect. Notification No. 9753 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 has entered into force and shall be given effect under section 90 of the Income-tax Act, 1961. Article 1 defines the personal scope: the Convention applies to persons who are residents of one or both Contracting States, establishing residency as the eligibility criterion for the treaty's provisions.