Revisional power in block assessment upheld, undisclosed search income sustained, freight suppression addition restored, accrued lorry hire liability ...
Reassessment and fee-for-technical-services classification: reopening upheld, but certain reimbursements and mobilization charges fell outside treaty ...
Section 80P deduction for co-operative societies remains available despite nominal members and housing society status, with limited interest income tr...
Under Article 8 of the India-France DTAA, collection charges retained from PSF/UDF were treated as an incentive for timely remittance and were held not directly connected with the operation of aircraft in international traffic, so the assessee's exclusion claim failed. Technical handling income from IATP/Non-IATP members was treated as profits from participation in a pool and retained its Article 8 character. Interest on fixed deposits from surplus or security funds connected with airline operations was treated as interest on funds connected with aircraft operations and covered by Article 8. Commission from the domestic leg of international travel was also treated as directly connected with international traffic and fell within Article 8.
Under Article 8 of the India-France DTAA, collection charges retained from PSF/UDF were treated as an incentive for timely remittance and were held not directly connected with the operation of aircraft in international traffic, so the assessee's exclusion claim failed. Technical handling income from IATP/Non-IATP members was treated as profits from participation in a pool and retained its Article 8 character. Interest on fixed deposits from surplus or security funds connected with airline operations was treated as interest on funds connected with aircraft operations and covered by Article 8. Commission from the domestic leg of international travel was also treated as directly connected with international traffic and fell within Article 8.
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