https://www.taxtmi.com/caselaws?id=422152 Article 8(2)(b) of the India-USA DTAA covers only activities directly connected with an enterprise's own operation of aircraft in international traffic; baggage screening and aircraft handling services rendered to other airlines were treated as a separate commercial activity and not exempt on that basis. Article 8(4), however, extends treaty relief to profits from participation in a pool, joint business, or international operating agency; reciprocal services under the International Airlines Technical Pool were accepted as pool participation, so the related receipts were taxable only in the residence State. The connected penalty under section 271(1)(c) could not survive once the underlying addition was deleted, and the issue was also regarded as debatable. en-us Tue, 12 Apr 2022 00:00:00 +0530 Tue, 10 May 2022 18:17:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=422152 Article 8(2)(b) of the India-USA DTAA covers only activities directly connected with an enterprise's own operation of aircraft in international traffic; baggage screening and aircraft handling services rendered to other airlines were treated as a separate commercial activity and not exempt on that basis. Article 8(4), however, extends treaty relief to profits from participation in a pool, joint business, or international operating agency; reciprocal services under the International Airlines Technical Pool were accepted as pool participation, so the related receipts were taxable only in the residence State. The connected penalty under section 271(1)(c) could not survive once the underlying addition was deleted, and the issue was also regarded as debatable. Case-Laws Income Tax Tue, 12 Apr 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=422152