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Foreign Courts Decisions
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....classified as royalty by one country and business income by another country. Therefore, reliance on foreign court rulings may result in harmonious interpretation. In many of the rulings Indian courts have referred to the foreign court cases for interpretation of treaty provisions. In CIT v. Vishakhapatnam Port Trust's case [1983] 144 ITR 146, the Andhra Pradesh High Court observed that, "in view ....