Assessee, a UK tax resident airline, had a branch office in India. Assessee was engaged in business of transportation of passengers, mail, livestock and goods by air through aircraft in international traffic and received delivery order charges. Assessing Officer held that said charges were taxable in India as same were derived from an activity subsequent to the transportation of goods in international traffic. Tribunal held that  expression ‘operation of aircraft’ in clause (3) of article 8 not only includes transportation by air, but it also includes the sale of tickets for such transportation, the incidental lease of aircraft on a charter basis, and any other activity directly connected with such transportation. Since the assessee was complying with delivery orders which were inextricably linked to the main activity of transportation by air of goods or mail in international traffic, the delivery order charges received by the assessee would not be taxable in India. (AY. 2020-21, 2021-22)