https://www.taxtmi.com/caselaws?id=779005 ITAT MUMBAI upheld the lower authority's finding that receipts from international passenger and cargo transportation performed wholly or partly by third-party carriers fall within Article 8 of the India-US DTAA and are fully exempt. The bench followed its earlier coordinate-bench decision for the relevant AY, noting no material change in facts or law and that the revenue did not rebut that precedent. Because all receipts were held exempt under Article 8, arguments on Article 8(2)(a) and 8(4) were treated as academic. 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 ITAT MUMBAI upheld the lower authority's finding that receipts from international passenger and cargo transportation performed wholly or partly by third-party carriers fall within Article 8 of the India-US DTAA and are fully exempt. The bench followed its earlier coordinate-bench decision for the relevant AY, noting no material change in facts or law and that the revenue did not rebut that precedent. Because all receipts were held exempt under Article 8, arguments on Article 8(2)(a) and 8(4) were treated as academic. Case-Laws Income Tax Fri, 19 Sep 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=779005