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    <title>2026 (4) TMI 1457 - ITAT DELHI</title>
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    <description>Under the India-France DTAA, receipts are exempt where they arise from, or are directly connected with, the operation of aircraft in international traffic, including treaty-recognised pool participation. Collection charges retained from PSF/UDF remittances were treated as an incentive or discount with no direct nexus to aircraft operations, and were therefore taxable in India. By contrast, technical handling income from IATP and non-IATP members, interest on fixed deposits linked to aircraft-operation funds, and commission from the domestic leg of an integrated international journey were held to fall within Article 8 and remain exempt.</description>
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