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    <title>2026 (8) TMI 202 - ITAT DELHI</title>
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    <description>Article 8 of the India-United Kingdom tax treaty exempts profits from operating aircraft in international traffic and qualifying pool participation, but not independent engineering and ground-handling services supplied to other airlines. Such services are organised commercial activities unconnected with the airline&#039;s own international transportation and therefore remain taxable in India. Cash deposits during demonetisation were treated as explained where deposit slips and accounts showed ordinary airport-counter collections from passengers and cargo agents, the receipts were recorded in the books, no defects were found, and collection patterns were not abnormal. The treaty exemption claim fails, while deletion of the unexplained cash-deposit addition remains undisturbed.</description>
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    <pubDate>Thu, 30 Jul 2026 00:00:00 +0530</pubDate>
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      <title>2026 (8) TMI 202 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=796329</link>
      <description>Article 8 of the India-United Kingdom tax treaty exempts profits from operating aircraft in international traffic and qualifying pool participation, but not independent engineering and ground-handling services supplied to other airlines. Such services are organised commercial activities unconnected with the airline&#039;s own international transportation and therefore remain taxable in India. Cash deposits during demonetisation were treated as explained where deposit slips and accounts showed ordinary airport-counter collections from passengers and cargo agents, the receipts were recorded in the books, no defects were found, and collection patterns were not abnormal. The treaty exemption claim fails, while deletion of the unexplained cash-deposit addition remains undisturbed.</description>
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