S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-Profits derived from baggage screening services and aircraft handling services provided to other airlines-Will not come within ambit of ‘other activity directly connected to such transport-Not covered under article 8(1)-Technical Pool (IATP)-Services from airlines on reciprocal basis, profit derived from providing baggage screening services and aircraft handling services to other airlines as a participant of IATP pool would be covered under article 8(1) read with article 8(4) DTAA-India-USA. [Art.7, 8(1),8(2), 8(4)]
United Airlines v. Dy. CIT (2022) 218 TTJ 698 / 138 taxmann.com 137 (Delhi)(Trib)