ITAT Mumbai Allows Exemption for Code-Sharing Income under Article 8 of India-USA DTAA

Delta Air Lines Vs DCIT (International Taxation) (ITAT Mumbai) The case involves four appeals filed by the assessee before the Income Tax Appellate Tribunal (ITAT) Mumbai against separate orders of the NFAC/CIT(A) dated 4 June 2024 for Assessment Years (AY) 2007-08, 2011-12, 2012-13, and 2013-14. As the issues involved were common across all years except for variations in figures, the Tribunal heard the appeals together and issued a common order, treating AY 2007-08 as the lead case. The primary issues raised by the assessee included the validity of reassessment proceedings under Section 147 o...