Court observed that  while interpreting double taxation avoidance agreements  with other States  have to be interpreted liberally  with a view to implement  the true intention of parties. Mere  position taken by India with respect to OECD commentary  do not alter the DTAA’s provisions , unless the latter are actually amended by way of bilateral re -negotiation . The OCED Commentary on  article 12 of the OECD Model Tax Convention in the DTAAs will continue to have persuasive value as to interpretation of the term   “royalties “ contained therein.