Member Airlines Can Offer Services to Non-IATP Members Under Article 8(2) of India-France DTAA.

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....Accrual of income in India - IATP manual clearly set out that there is no bar on member airline to provide service to non IATP Pool member and in fact, even non IATP Pool members if takes such service from a pool would be considered as a pool service to them. Thus, the assessee being a pool member and providing service in that capacity to the guest members comes under the purview of Article 8(2) of the DTAA between India and France.....