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    <description>Delivery order charges received for cargo transportation by air in international traffic were held to fall within Article 8 of the India-UK DTAA because they formed an integral part of aircraft operations. The charges were not treated as a separate business activity; issuance and compliance with delivery orders were directly connected with the movement and delivery of goods or mail in international traffic. On that basis, the receipts were covered by treaty protection for profits from aircraft operations and were not taxable in India.</description>
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