TAXATION - allocation of taxing rights - interaction between Art 7 and Art 12 of the Agreement between the Government of Australia and the Government of the Republic of India for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income 1991 [1991] ATS 49 - operation of Art 7 "business profits rule" - operation of Art 12 "the royalties provision" - whether Art 12(4) on its proper construction applied to royalties - whether source State has a right to tax royalties under Art 7 or Art 12
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