https://www.taxtmi.com/caselaws?id=795267 Article 8 of the India-UK tax treaty exempts profits from operating aircraft in international traffic, including qualifying pool participation and activities directly connected with air transportation. Ground handling and engineering services supplied to other airlines were characterised as an organised commercial activity, not a pool arrangement based on common resources and profit sharing, and were not directly connected with the provider's own international air transportation. Treaty decisions under the India-Germany and India-Netherlands agreements were distinguishable because those treaties differed materially. OECD commentary could not enlarge the treaty's scope, particularly given India's reservation on ancillary activities. Accordingly, these receipts are taxable in India and do not qualify for Article 8 exemption. en-us Tue, 14 Jul 2026 00:00:00 +0530 Mon, 20 Jul 2026 09:37:31 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=795267 Article 8 of the India-UK tax treaty exempts profits from operating aircraft in international traffic, including qualifying pool participation and activities directly connected with air transportation. Ground handling and engineering services supplied to other airlines were characterised as an organised commercial activity, not a pool arrangement based on common resources and profit sharing, and were not directly connected with the provider's own international air transportation. Treaty decisions under the India-Germany and India-Netherlands agreements were distinguishable because those treaties differed materially. OECD commentary could not enlarge the treaty's scope, particularly given India's reservation on ancillary activities. Accordingly, these receipts are taxable in India and do not qualify for Article 8 exemption. Case-Laws Income Tax Tue, 14 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=795267