Delta’s Code-Share Revenue Exempt Under DTAA: ITAT Mumbai

DCIT Vs Delta Air Lines (ITAT Mumbai) Third-Party Carriers Still Covered by Article 8 – Tribunal Protects DTAA Exemption- Code-Sharing Revenue Not Taxable in India – ITAT Mumbai Rules in Delta’s Favour Assessee, a tax resident of USA, was engaged in international air traffic operations & had a branch office in India approved by RBI & DGCA. While income from operations through its own aircrafts was not in dispute, the controversy centered around revenues earned where passengers or cargo were carried either partly or wholly through third-party airlines under code-sharing agreements...