Delivery Order Income Held “Directly Connected” to Air Transport, Exempt Under Article 8 UK DTAA

Virgin Atlantic Airways Ltd Vs DCIT (ITAT Delhi) Assessee, a tax resident of UK operating aircraft in International Traffic, challenged addition of ₹2,62,84,839/- (AY 2020-21) & ₹3,44,84,410/- (AY 2022-23) towards delivery order charges on cargo consignments. AO held that these were taxable in India as income from activities subsequent to transportation. CIT(A) upheld the additions. Before Tribunal, Assessee argued that delivery order charges are an integral & inseparable part of air-cargo transportation, falling within “any other activity directly connected with such transportat...