https://www.taxtmi.com/caselaws?id=761829 Receipts from an airline's code-sharing arrangements were treated as profits from the operation of aircraft in international traffic under Article 8 of the India-USA Tax Treaty. The Tribunal found the arrangement commercially and factually integrated with the airline's core international air-transport business because tickets were issued under the airline's code for the whole journey, the third-party carriage was on a principal-to-principal basis, and the activity was comparable to chartering space rather than a mere agency function. On that basis, the receipts qualified for treaty exemption and were not taxable in India. en-us Thu, 07 Nov 2024 00:00:00 +0530 Thu, 14 Nov 2024 14:23:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=761829 Receipts from an airline's code-sharing arrangements were treated as profits from the operation of aircraft in international traffic under Article 8 of the India-USA Tax Treaty. The Tribunal found the arrangement commercially and factually integrated with the airline's core international air-transport business because tickets were issued under the airline's code for the whole journey, the third-party carriage was on a principal-to-principal basis, and the activity was comparable to chartering space rather than a mere agency function. On that basis, the receipts qualified for treaty exemption and were not taxable in India. Case-Laws Income Tax Thu, 07 Nov 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=761829