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The ITAT allowed the appeal, holding that delivery order charges received by the assessee in its air-cargo business are integral to and "directly connected with" international air transportation and therefore fall within Article 8(2)(b) of the applicable tax treaty; such receipts are taxable in the Contracting State and not taxable in India. The Tribunal reversed the lower authorities' additions, accepted the assessee's substantive ground as covered by its earlier decision for the relevant assessment year, and directed deletion of the impugned taxability of delivery order charges in India. The revenue's assessment treating those receipts as Indian taxable income was set aside.
The ITAT allowed the appeal, holding that delivery order charges received by the assessee in its air-cargo business are integral to and "directly connected with" international air transportation and therefore fall within Article 8(2)(b) of the applicable tax treaty; such receipts are taxable in the Contracting State and not taxable in India. The Tribunal reversed the lower authorities' additions, accepted the assessee's substantive ground as covered by its earlier decision for the relevant assessment year, and directed deletion of the impugned taxability of delivery order charges in India. The revenue's assessment treating those receipts as Indian taxable income was set aside.
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