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    <title>2023 (2) TMI 1165 - ITAT DELHI</title>
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    <description>Receipts from technical handling services for IATP member airlines were held to fall within Article 8(2) of the India-France DTAA because they arose from reciprocal pool participation; the addition was deleted. The same treaty treatment was extended to technical handling services for non-IATP member airlines, as the pool manual did not bar such services and they were treated as pool services; the addition was deleted. Interest on fixed deposits created from funds connected with aircraft operations in international traffic was treated as profits from such operation under Article 8(3) and held not taxable in India. Collection charges for UDF/PSF were not directly connected with aircraft operations and were taxable, while commission for arranging the domestic leg of an international journey was held directly connected with such operations and exempt.</description>
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      <description>Receipts from technical handling services for IATP member airlines were held to fall within Article 8(2) of the India-France DTAA because they arose from reciprocal pool participation; the addition was deleted. The same treaty treatment was extended to technical handling services for non-IATP member airlines, as the pool manual did not bar such services and they were treated as pool services; the addition was deleted. Interest on fixed deposits created from funds connected with aircraft operations in international traffic was treated as profits from such operation under Article 8(3) and held not taxable in India. Collection charges for UDF/PSF were not directly connected with aircraft operations and were taxable, while commission for arranging the domestic leg of an international journey was held directly connected with such operations and exempt.</description>
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