Hitopdesh • Chapter 5 • Shloka 115
कपालसंधिर्विज्ञेयः केवलं समसंधितः ।
संप्रदानाद् भवति य उपहारः स उच्यते ॥
That is known to be Kapala Samdhi (treaty) which is formed on equal terms (or between equal parties), while that is called Upahara which is brought about by (one of the parties giving) gifts (to the other).
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