‘Most Favoured Nation’ clause can be referred to interpret treaties and not to import ‘make-availabl

IT/ILT: The applicant contended that in view of Protocol to India-France DTAA, are stricted scope of the term FTS should be applied as provided for in any treaty entered into between India and a third State - Hence, when there was no 'make available' clause in the India-France Treaty, the restricted scope of FTS in the India-UK DTAA had to be applied - Held: Authority held that Protocol or Memorandum can be made use of for interpreting provision of the Treaty -It will be inappropriate to import