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of <h1>Courts Interpret Tax Treaties Differently; Indian Courts Reference Global Rulings for Consistency in Treaty Interpretation.</h1> Tax treaties are often interpreted differently by courts in different countries, leading to inconsistencies. For example, the same income might be considered royalty in one country and business income in another. Indian courts frequently reference foreign court decisions to interpret treaty provisions, as seen in cases like Union of India v. Azadi Bachao Andolan and CIT v. Vishakhapatnam Port Trust. The Andhra Pradesh High Court emphasized the importance of considering global rulings to maintain uniformity in treaty interpretation, highlighting the development of international tax law influenced by the standard OECD Models.
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