47. Debts to persons resident in foreign country not to be deducted in first instance except from duty- paid property in that country. An allowance shall not be made in the first instance for debts due from the deceased to persons resident 3[ out of India] (unless contracted to be paid in 4[ India] or charged on properties situate within 4[ India]) except out of the value of any property of the deceased situate out of 4[ India] in respect of which estate duty is paid; and there shall be no repayment of estate duty in respect of any such debts, except to the extent to which it is shown to the satisfaction of the Controller that the property of the deceased situate in the foreign country in which the person to whom such debts are due resides is insufficient for their payment.