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Article 8 treaty coverage excluded third-party airline support services, while documented demonetisation cash receipts remained accepted business income.
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Article 8 of the India-UK DTAA exempts profits from operating aircraft in international traffic and participation in pools, but engineering and ground handling services provided to other airlines were not treated as pool participation or activities directly connected with air transportation under the treaty. Unlike broader provisions in certain other treaties, the India-UK provision did not cover those receipts; they remained taxable in India. Cash deposits made during demonetisation were accepted as regular airline business receipts because they were recorded in the books, arose from airport counter collections from passengers and cargo agents, and no specific defect in the books was identified. The deletion of the related addition was sustained.
Article 8 of the India-UK DTAA exempts profits from operating aircraft in international traffic and participation in pools, but engineering and ground handling services provided to other airlines were not treated as pool participation or activities directly connected with air transportation under the treaty. Unlike broader provisions in certain other treaties, the India-UK provision did not cover those receipts; they remained taxable in India. Cash deposits made during demonetisation were accepted as regular airline business receipts because they were recorded in the books, arose from airport counter collections from passengers and cargo agents, and no specific defect in the books was identified. The deletion of the related addition was sustained.
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