https://www.taxtmi.com/caselaws?id=59722 Article 8 of the Indo-US treaty was construed strictly according to its own definition, so exemption for air-transport profits could not be expanded by model-convention commentary. Income from security screening, charter handling and similar services for third-party airlines was treated as outside the treaty scope because it was not transportation by the assessee as owner, lessee or charterer of aircraft. Interest on fixed deposits was also held outside Article 8(5) because the deposits lacked a direct nexus with aircraft operation, maintenance or rental in international traffic. Interest under section 234B was not sustained where tax was deductible at source under section 195. en-us Mon, 29 Sep 2008 00:00:00 +0530 Sat, 09 Dec 2023 19:26:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=59722 Article 8 of the Indo-US treaty was construed strictly according to its own definition, so exemption for air-transport profits could not be expanded by model-convention commentary. Income from security screening, charter handling and similar services for third-party airlines was treated as outside the treaty scope because it was not transportation by the assessee as owner, lessee or charterer of aircraft. Interest on fixed deposits was also held outside Article 8(5) because the deposits lacked a direct nexus with aircraft operation, maintenance or rental in international traffic. Interest under section 234B was not sustained where tax was deductible at source under section 195. Case-Laws Income Tax Mon, 29 Sep 2008 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=59722