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1998 (3) TMI 107 - KARNATAKA HIGH COURTExtract: .......mercial profit. Therefore, it is not liable to be taxed in India under the Double Taxation Agreement referred to above under article III(1) of the above articles. Therefore, we answer question No. 1 in favour of the assessee and against the Revenue. In view of the above answer, it is not necessary to answer the second question. I.T.R.C. is allowed.
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