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    <title>2025 (10) TMI 428 - ITAT DELHI</title>
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    <description>Delivery order charges received in connection with cargo transportation were treated as part of profits from the operation of aircraft in international traffic because they arose from handing over goods to the consignee and were directly connected with the airline&#039;s transport activity. Article 8(1) of the India-Turkey DTAA allocates such profits to the State of residence, and Article 8(2)(b) extends the rule to other activities directly connected with international air transport. On that basis, the charges were covered by Article 8 and were not taxable in India.</description>
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      <description>Delivery order charges received in connection with cargo transportation were treated as part of profits from the operation of aircraft in international traffic because they arose from handing over goods to the consignee and were directly connected with the airline&#039;s transport activity. Article 8(1) of the India-Turkey DTAA allocates such profits to the State of residence, and Article 8(2)(b) extends the rule to other activities directly connected with international air transport. On that basis, the charges were covered by Article 8 and were not taxable in India.</description>
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