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As per treaty with USA Profits attributable to transaction of cargo, mail, etc. by aircrafts owned, chartered or leased by assessee cannot be taxed in India
Case Law Details
- Case Name
- ADIT (International Taxation) Vs. Federal Express Corporation (ITAT Mumbai)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Courts
- ITAT Mumbai
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CASE LAWS DETAILS
DECIDED BY: ITAT, MUMBAI BENCH `L’, MUMBAI
IN THE CASE OF: ADIT (International Taxation) Vs. Federal Express Corporation, USA, Appeal No: ITA Nos. 4452, 4453 & 9482/2004, DECIDED ON: January 29, 2009
RELEVANT PARAGRAPH
27. Rival submissions of the parties have been considered carefully in the light of the material placed before us and the case laws referred to. The first question for our consideration is whether the benefit of Article 8 of the Indo U.S. Treaty can be denied to the assessee merely on the ground that the nature of activity carried on ...
