Tax treaty exemption for operation of airline and cargo services...

Tax treaty exemption for operation of airline and cargo services was held applicable, the competent authority's issuance of a certificate at a reduced withholding rate rested on an incorrect belief about outstanding assessments and thus reflected non-application of mind and inconsistent administration; because assessments showed no tax payable for the airline services, the HC set aside the impugned certificate and directed issuance of a NIL-rate certificate within seven days. The court noted taxable ground-handling and engineering services remain payable and were not affected.

---