COMMISSIONER OF INCOME TAX ANDHRA PRADESH Vs. VISAKHAPATNAM PORT TRUST

JUDGEMENT

(1.) Questions relating to the interpretation of International Tax Agreements containing international tax language fall for consideration in this reference.

(2.) The question of law referred to us at the instance of the Commissioner of Income-tax, Andhra Pradesh, Hyderabad, is as follows :

(3.) The Income-tax Appellate Tribunal, Hyderabad, has consolidated 21 reference applications as common question are involved and it has drawn up a single reference application.