Double Taxation Agreement personal scope covers residents of one or both states; treaty provisions given effect under domestic law.

The Central Government has directed that the Agreement for the Avoidance of Double Taxation and the prevention of fiscal evasion with respect to taxes on income be given effect under section 90 of the Income-tax Act, integrating treaty provisions into domestic law. The Agreement's personal scope extends to persons who are residents of one or both Contracting States, making residency the defining criterion for entitlement to treaty benefits and obligations.

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