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    <description>Collection charges received from the airport authority for timely remittance of User Development Fee were treated as a separate service-related receipt, not as profit derived from the operation of aircraft in international traffic. The receipt lacked a direct nexus with the actual operation of aircraft and was not incidental to such operation, so Article 8 exemption did not apply. Following the prior coordinate bench decision on identical facts, the amount was held taxable in India.</description>
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