(1) In this Agreement, unless the context otherwise requires:
- (a) the terms "a Contracting State" and "the other Contracting State" mean the Republic of India (India) or the Union of Soviet Socialist Republics (the U.S.S.R.), as the context requires;
- (b) the term "person" means an individual, and:
- (i) in the case of India, also a company or any other entity which is treated as a taxable unit under the taxation laws in force in India;
- (ii) in the case of the U.S.S.R., also any legal person or other organisation, created under the laws of the U.S.S.R. or any Union Republic and treated as a legal person for the purposes of taxation in the U.S.S.R.;
- (c) the term "competent authority" means;
- (i) in the case of India, the Ministry of Finance (Central Government, Department of Revenue) or its authorized representative;
- (ii) in the case of the U.S.S.R., the Ministry of Finance of the U.S.S.R. or its authorized representative;
- (d) the term "national" means:
- (i) in the case of India, any individual possessing the nationality of India and any legal person, partnership or association deriving its status from the laws in force in India;
- (ii) in the case of the U.S.S.R., any individual possessing the citizenship of the U.S.S.R. and any legal person deriving its status from the laws in force in the U.S.S.R.;
- (e) the term "international traffic" means any transport by a ship or aircraft operated by a resident of a Contracting State except when the ship or aircraft is operated solely between places in the other Contracting State;
- (f) the term "fiscal year" means:
- (i) in the case of India, the "previous year", as defined in the Income-tax Act, 1961;
- (ii) in the case of the U.S.S.R., the period commencing on the 1st of January and ending on the 31st of December.
(2) As regards the application of the Agreement by a Contracting State, any term not defined therein shall, unless the context otherwise requires, have the meaning which it has under the law of that State concerning the taxes to which the Agreement applies.