https://www.taxtmi.com/caselaws?id=779005 Receipts from passenger and cargo transportation under code-sharing arrangements were treated as falling within Article 8 of the India-USA DTAA because they form part of the airline's "operation of aircrafts" in international traffic. The Tribunal accepted that journeys performed wholly or partly through third-party carriers remained inextricably linked to the assessee's air transport business and were carried on on a principal-to-principal basis. It also relied on the earlier year's identical ruling and noted no material change in facts or law was shown to depart from that view. The receipts were therefore held not taxable in India. en-us Fri, 19 Sep 2025 00:00:00 +0530 Fri, 26 Sep 2025 08:26:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=779005 Receipts from passenger and cargo transportation under code-sharing arrangements were treated as falling within Article 8 of the India-USA DTAA because they form part of the airline's "operation of aircrafts" in international traffic. The Tribunal accepted that journeys performed wholly or partly through third-party carriers remained inextricably linked to the assessee's air transport business and were carried on on a principal-to-principal basis. It also relied on the earlier year's identical ruling and noted no material change in facts or law was shown to depart from that view. The receipts were therefore held not taxable in India. Case-Laws Income Tax Fri, 19 Sep 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=779005