https://www.taxtmi.com/caselaws?id=63565 Receipts from reciprocal line maintenance and technical support under the International Airlines Technical Pool arrangement were treated as profits from participation in a pool under Article 8(4) of the Indo-German tax treaty. The Tribunal held that the arrangement was governed by the pool framework, including the relevant manual and prescribed forms, and that the reciprocal nature of the services brought the profits within the specific air-transport allocation rule. It further noted that the general business profits and permanent establishment provisions could not override Article 8 for such income, so the receipts were not taxable in India. en-us Thu, 12 Feb 2004 00:00:00 +0530 Tue, 25 Jun 2024 16:19:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=63565 Receipts from reciprocal line maintenance and technical support under the International Airlines Technical Pool arrangement were treated as profits from participation in a pool under Article 8(4) of the Indo-German tax treaty. The Tribunal held that the arrangement was governed by the pool framework, including the relevant manual and prescribed forms, and that the reciprocal nature of the services brought the profits within the specific air-transport allocation rule. It further noted that the general business profits and permanent establishment provisions could not override Article 8 for such income, so the receipts were not taxable in India. Case-Laws Income Tax Thu, 12 Feb 2004 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=63565