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The ITAT affirmed the appellate authority's decision, holding that the taxpayer's receipts from international carriage of passengers and cargo, including services performed entirely by third-party carriers pursuant to code-sharing arrangements, constitute "operation of aircraft in international traffic" within the meaning of Article 8 of the India-US DTAA and are exempt from Indian taxation. The Tribunal applied the coordinate-bench precedent for the relevant assessment year, finding no material change in facts or law and no persuasive revenue evidence to the contrary. Because the entire receipts were held exempt under Article 8, subsidiary contentions regarding Article 8(2)(a) and Article 8(4) were declared academic.
The ITAT affirmed the appellate authority's decision, holding that the taxpayer's receipts from international carriage of passengers and cargo, including services performed entirely by third-party carriers pursuant to code-sharing arrangements, constitute "operation of aircraft in international traffic" within the meaning of Article 8 of the India-US DTAA and are exempt from Indian taxation. The Tribunal applied the coordinate-bench precedent for the relevant assessment year, finding no material change in facts or law and no persuasive revenue evidence to the contrary. Because the entire receipts were held exempt under Article 8, subsidiary contentions regarding Article 8(2)(a) and Article 8(4) were declared academic.
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