https://www.taxtmi.com/caselaws?id=213233 Article 8 of the India-USA DTAA was read narrowly: profits from the operation of aircraft in international traffic were confined to income derived from transportation by the owner, lessee or charterer and specified directly connected activities. Line-haul charges earned from moving cargo through other airlines were not treated as falling within that definition under Article 8(2) on the facts found. The Tribunal nevertheless left open examination of paragraph 4 of Article 8 and whether the arrangements could amount to transport by chartered aircraft, and remitted the matter for limited fresh consideration on those issues. en-us Wed, 14 Mar 2012 00:00:00 +0530 Fri, 22 Apr 2016 14:57:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=213233 Article 8 of the India-USA DTAA was read narrowly: profits from the operation of aircraft in international traffic were confined to income derived from transportation by the owner, lessee or charterer and specified directly connected activities. Line-haul charges earned from moving cargo through other airlines were not treated as falling within that definition under Article 8(2) on the facts found. The Tribunal nevertheless left open examination of paragraph 4 of Article 8 and whether the arrangements could amount to transport by chartered aircraft, and remitted the matter for limited fresh consideration on those issues. Case-Laws Income Tax Wed, 14 Mar 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=213233