Profits from transport of air passengers covered under Article 8 of Indo-Bhutan DTAA

DCIT Vs Tashi Air Pvt. Ltd (ITAT Kolkata) Assessing Officer has rejected the claim of the assessee only on the ground that the term ‘Profits derived from the operation of ships or aircraft in international traffic’ has been more elaborately explained to include the transportation of air passengers. “4. For the purposes of this Article, profits from the operation of ships or aircraft in international traffic shall mean profits derived from the transportation by sea or air of passengers, mail, livestock or goods carried on by the owners or lessees or charterers of the ships or airc...