https://www.taxtmi.com/caselaws?id=429042 Article 8 of the India-Bhutan DTAA is described as giving exclusive taxing rights over profits from aircraft operations in international traffic to the State where the place of effective management is situated. On the stated facts, that place was found to be Bhutan, so the treaty applied in preference to section 9 of the Income-tax Act, 1961 under section 90(2). The analysis states that sale proceeds from tickets and allied airline receipts were covered by the treaty rule, and the income was therefore taxable only in Bhutan and not in India. en-us Wed, 12 Oct 2022 00:00:00 +0530 Sat, 15 Oct 2022 14:58:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=429042 Article 8 of the India-Bhutan DTAA is described as giving exclusive taxing rights over profits from aircraft operations in international traffic to the State where the place of effective management is situated. On the stated facts, that place was found to be Bhutan, so the treaty applied in preference to section 9 of the Income-tax Act, 1961 under section 90(2). The analysis states that sale proceeds from tickets and allied airline receipts were covered by the treaty rule, and the income was therefore taxable only in Bhutan and not in India. Case-Laws Income Tax Wed, 12 Oct 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=429042