https://www.taxtmi.com/caselaws?id=304603 Only profits directly derived from the operation of aircraft in international traffic qualify for Article 8 treaty protection. Amounts received for collecting user development fee from passengers and remitting it to the airport authority were treated as service charges for a separate function, whether described as discount or commission, and not as income from aircraft operations. The receipts were therefore taxable in India as business income. The addition relating to the collection charges was sustained, and the related interest and penalty grounds failed as consequential or premature. en-us Thu, 24 Mar 2022 00:00:00 +0530 Mon, 10 Oct 2022 10:05:04 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=304603 Only profits directly derived from the operation of aircraft in international traffic qualify for Article 8 treaty protection. Amounts received for collecting user development fee from passengers and remitting it to the airport authority were treated as service charges for a separate function, whether described as discount or commission, and not as income from aircraft operations. The receipts were therefore taxable in India as business income. The addition relating to the collection charges was sustained, and the related interest and penalty grounds failed as consequential or premature. Case-Laws Income Tax Thu, 24 Mar 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=304603