India-UAE Tax Treaty: Are Time Charters and Slot Hires Covered Under Article 8? Clarifying 'Liable to Tax' Status.

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....Benefit of DTAA between India and UAE - whether time charter and hiring of slots fell within the Article 8 of the Treaty or not. - Simply because there is no tax incidence in UAE, does not mean that the assessee ceases to be 'otherwise liable to tax', as per Article 4. - AT....