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    <title>Delivery order charges for international air-cargo are part of transportation under Article 8(2)(b), not domestically taxable</title>
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    <description>The ITAT allowed the appeal, holding that delivery order charges received by the assessee in its air-cargo business are integral to and &quot;directly connected with&quot; international air transportation and therefore fall within Article 8(2)(b) of the applicable tax treaty; such receipts are taxable in the Contracting State and not taxable in India. The Tribunal reversed the lower authorities&#039; additions, accepted the assessee&#039;s substantive ground as covered by its earlier decision for the relevant assessment year, and directed deletion of the impugned taxability of delivery order charges in India. The revenue&#039;s assessment treating those receipts as Indian taxable income was set aside.</description>
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    <pubDate>Thu, 09 Oct 2025 08:54:39 +0530</pubDate>
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      <title>Delivery order charges for international air-cargo are part of transportation under Article 8(2)(b), not domestically taxable</title>
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      <description>The ITAT allowed the appeal, holding that delivery order charges received by the assessee in its air-cargo business are integral to and &quot;directly connected with&quot; international air transportation and therefore fall within Article 8(2)(b) of the applicable tax treaty; such receipts are taxable in the Contracting State and not taxable in India. The Tribunal reversed the lower authorities&#039; additions, accepted the assessee&#039;s substantive ground as covered by its earlier decision for the relevant assessment year, and directed deletion of the impugned taxability of delivery order charges in India. The revenue&#039;s assessment treating those receipts as Indian taxable income was set aside.</description>
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